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A commenter requested that our definition be revised to remove the exclusion of services with 010 or 090 global surgery indicators and allow virtual direct supervision for all services paid under the PFS, since we have revised many telehealth policies to defer to clinical judgment throughout this final rule

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The measured position is that the pathway is important and GHK-Cu is pleiotropic, so overlap is likely — but a clean, primary demonstration that GHK-Cu drives Wnt-dependent anagen in human follicles is not something the record firmly establishes