There’s a reason that CMS is talking about “package pricing” of CTPs (aka “skin substitutes”) in the doctor’s office. Proposed policies from CMS do not come out of nowhere. CMS notes changes in the volume of claims and then tackles those changes with policies. The auditors take over from there, and then the Office of the Inspector General (OIG) gets involved. Now, the OIG is very busy looking at practices with high utilization of CTPs. Based on public information, some manufacturer relationships with physicians and institutions are outside the law, and there’s also an overuse/abuse problem. What has come out in the news is the tip of the iceberg based on the emails and phone calls that I have been getting from practitioners. It’s hard to make the case to CMS that patients are going to be hurt when at the moment, the data suggest that it’s the tax payers that are being hurt.

This situation is hurting all the reputable doctors trying to use CTPs appropriately. In response to the egregious misuse by some, the documentation of every doctor is being picked apart under a microscope. When an auditor is compensated with a portion of the money that gets recouped, they ARE going to find deficiencies in documentation. Anyone using CTPs had better pay very careful attention to documentation requirements. It’s not “if” you will be audited, but WHEN. I am not fear-mongering. Heads up on this everyone.