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Response: After reviewing the information provided by the commenter and following consultation with our medical officers, we have determined that this equipment is only used in conjunction with another procedure and would be packaged for payment consistent with our policy of packaging items and services that are typically integral, ancillary, supportive, dependent, or adjunctive to a primary service

Eussen, 2005

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Discovered in human plasma back in the 1970s, GHK-Cu has spent decades proving itself in wound healing and skin regeneration research

FDA may not follow PCACs recommendation under the Drug Quality and Security Act framework