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If a consortium uses an annual membership fee instead of billing each member for actual services, would this fee be interpreted as “reselling”?

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If a consortium uses an annual membership fee instead of billing each member for actual services, would this fee be interpreted as “reselling”?

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An eligible entity cannot apply for reimbursement for such membership fee. Any membership fee will have to be broken out to determine what the exact fee is for each service provided by membership in consortium so that only eligible services can be identified.

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