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!