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The word "copper" appearing next to a botanical extract or in a trade name does not mean a copper-peptide complex is present

Response: We disagree with the commenter's interpretation that these diagnostic radiopharmaceuticals would remain policy-packaged under 42 CFR 419.2(b)(15) after we implemented the CY 2025 diagnostic radiopharmaceuticals separate payment policy (89 FR 93948)

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When available, review the current COA, HPLC chromatogram, and MS document

Pickart has developed a high concentration of GHK-Cu (3%) copper peptide blended with skin-healthy emulsifiers to further enhance visible results