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

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
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