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Response: Although we acknowledge the applicant's concerns regarding the descriptor for C1739, we do not agree that the device category code should be withdrawn and replaced with a new code effective January 1, 2026, for the following reasons: First, per the applicant's request prior to CY 2026 rulemaking, CMS revised the descriptor for C1739 to read, effective October 1, 2025: Tissue marker, uniquely detectable and identifiable with probe/sensor, any method (implantable), with delivery system

The dose stays consistent while the frequency decreases, followed by 48 weeks off

Cell 162 , 12711285 (2015)

Cell morphology was observed using an inverted microscope (Leica, Germany)

Allergy warning: Manufactured in a facility that may process allergens