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To the contrary, for the reasons stated in the proposed rule (89 FR 61853), we continue to believe that the specific subpopulations of Medicare beneficiaries who are otherwise eligible for assignment to an entity participating in a disease- or condition-specific CMS Innovation Center model, but who may not be captured by 425.402(e)(2)(ii)(D) because their models consider primary care services for purposes of assignment, could benefit from the focused attention and increased care coordination offered by an entity participating in a disease- or condition-specific model

Apr 25 2021;13(4):e14671

Vitamin B12 deficiency is common amongst older adults who do not have enough hydrochloric acid in their stomach to absorb Vitamin B12 naturally, individuals who take stomach acid-altering medications or antibiotics frequently, individuals who have a gastrointestinal conditions, vegetarians/ vegans, and individuals with pernicious anemia

J Toxicol Clin Toxicol 42:163169 Tsao YT, Tsai WC, Yang SP (2008) A life-threatening double gap metabolic acidosis

There is no published human trial validating the combination's safety or efficacy specifically