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As we stated, the vast majority of hospitals have only one Type 2 NPI, and therefore we do not believe it would be overly burdensome to require hospitals to encode all Type 2 NPIs that have a primary taxonomy code starting with `28' or `27.' Furthermore, a review of the publicly available January 2025 data from PECOS, indicates that not all hospitals, such as psychiatric hospitals, have a Type 2 NPI with a primary taxonomy code starting with `28.' [485] Therefore, requiring both strikes a balance ensuring that all hospitals subject to the HPT requirements will have an NPI listed in their MRF

For references, see below

7 A product may be medicinal because it is presented for treating or preventing disease

Unless specified in batch documentation, the vial contains only the research-grade L-carnitine compound