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Kat Sienk's avatar

I'd guess double dipping. EUA products with Prep Act CICP and approved products with 1986 NCVIA VICP.

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Alex Eulenberg's avatar

Yeah, and to add to the confusion, “approved” and “licensed” (e.g. Comirnaty) products are covered by CICP just as well as EUA “authorized”, contrary to popular opinion:

“The COVID-19 therapeutic must be authorized, approved, or licensed by the FDA”

https://www.federalregister.gov/d/2021-19790/p-13

https://www.federalregister.gov/d/2021-19790/p-41

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