Has there been any movement at DPAP/CPIC in an effort to get this language changed?
Unfortunately it was decided that the language at PGI 201.602-2 (d) (v) (A) will not change. So, if you are not using SAP procedures, and thus can't meet the 3- part exemption, you must designate a COR. I'm sorry, but we do not know the rationale behind this decision.
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