At the November 2025 WG2 Meeting the form was discussed.
Clarification of Billing Unit Standard
©
New Product/Package Information
Request:
Beta Bionics is commercializing an insulin dosing patch pump. The product has a 1-year durable component (mint controller) and a disposable component (mint(s)) that will be used for 3 days and then disposed of.
Mint controller – a hard plastic piece which contains the motherboard, memory, Bluetooth radio, motor, and drive train for the purpose of receiving CGM values, computing algorithmic values, dosing insulin, and relaying the CGM value as well as other information to a patient’s phone or alternate display device.
Mint – a 200-unit (of u-100 insulin) reservoir which also includes the battery, needle, and adhesive backed cloth patch material.
For the refill kit, the components of the kit will be as follows: 5 mints. Each of the mints will be in a sterile tray that will also include a syringe and needle for the purpose of filling the 200-unit mint reservoir.
At the most common prescribed frequency of change, every 3 days, the patient will receive 2 boxes which contain a total of 10 mints and last 30 days. For patients with large insulin requirements, they will receive 3 boxes which contain a total of 15 mints.
Why Needed:
New to market product.
Outcome Anticipated:
Unit = eaches; Qty = 5
The box will contain 5 mints each of which are configured within a sterile tray also containing a syringe and needle for the purpose of filling the reservoir with insulin. Because of the tray configuration, the quantity counted are the trays making the quantity = 5.
This follows the logic of Insulet’s Omnipod refill kits.
Task Group Discussion (09/02/25):
- Each refill kit contains 5 sterile trays (5 Mints)
- Each sterile tray contains:
- A Mint reservoir, a syringe and needle for the purpose of filling the 200-unit Mint reservoir.
- All items supplied in each tray are sterile products intended to be used together
- Outer and inner packages (trays) have the same NDC number
- Because the contents of the sterile tray are intended to be used together and not separately, the task group agrees each tray should be counted as one unit. Section 5.5.1 of the BUS will be reviewed and updated to reflect this billing unit assignment and package size.
- Agreement of an assignment of BU = EA per section 5.5.1 of the BUS with a package size of 5 for each refill kit.
WG Discussion (11/07/25):
A motion was made and seconded to classify the BU = EA with a package size of 5 per section 5.5.1 of the Billing Unit Standard
©. The motion carried.