MACs’ LCD Revisions for CTPs (Skin Substitutes) are Out, and You Need to Read the Fine Print!

As I have already discussed, three Medicare Administrative Contractors (MACs) CGS, First Coast Service Option (FCSO) and Novitas issued their final Local Coverage Determinations (LCDs) for Cellular and/or tissue-based products (CTPs). These policies will go into effect on September 17, 2023. Links to the articles, which you should read in detail yourself, are provided below.

A few interesting points:

• CTPs are covered for DFUs that have failed to reduce by >50% in 4 weeks of standard of care (SOC) (note that the criteria used to be 30%!)
• CTPs are covered for VUs that have failed to “significantly progress” in 4 weeks of SOC – but no specific percentage of reduction is specified
• The “episode” of use of CTPs is defined as 12 weeks from 1st application of the CTP
• The policy states that a vascular evaluation is “vital for all chronic wounds” (not just VLUs!)
• Note that debridements are not covered in conjunction with repeat CTP applications!
• Also note that the products which require weekly replacement do not meet the definition of a graft. There’s a very long list of uncovered products!

There’s a lot in these LCDs so definitely read them for yourself!

• Article – Billing and Coding: Skin Substitute Grafts/Cellular and/or Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers (A57680) (cms.gov)
• Article – Billing and Coding: Skin Substitute Grafts/Cellular and/or Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers (A54117) (cms.gov)
• Article – Billing and Coding: Skin Substitutes Grafts/Cellular Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers (A56696) (cms.gov)

–Caroline

Caroline Fife, M.D.

Dr. Fife is a world renowned wound care physician dedicated to improving patient outcomes through quality driven care. Please visit my blog at CarolineFifeMD.com and my Youtube channel at https://www.youtube.com/c/carolinefifemd/videos

The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.