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1998 Mar

HOPDs will have approximately 25 months from the publication of this final rule with comment period until the start of the mandatory reporting period in January 2028, and approximately 3 and a half years from the publication of this final rule until the submission deadline for the CY 2028 data in May 2029

Theres insufficient safety data on GHK-Cu in pregnancy or breastfeeding

Not because it is the only device that can deliver GHK-Cu to the dermis, but because its design choices map cleanly onto the failure modes the literature has spent two decades pointing at