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Comment: Many commenters supported the proposal to continue using the mean of 75 points from CY 2017 performance period/2019 MIPS payment year for the CY 2026 performance period/2028 MIPS payment year
Considering the short half-life nature of peptides, of which BPC-157 is an example, it can initially be that the agent is generally safe
Response: We did not propose to change the allocation of indirect costs based on direct costs in the facility setting
For example, we sought comments on whether skin substitutes with active pass-through payment status under the OPPS and/or those receiving new technology add-on payments (NTAP) under the IPPS should be paid separately from their FDA category, similar to those approved via BLA under section 351 of the PHS Act, under the PFS
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Liposomal delivery systems encapsulate AHK-Cu in lipid spheres, potentially improving penetration through the stratum corneum and protecting the peptide from degradation
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