I have been trying to identify the problems in the CTP/skin sub industry in hopes that doing so could inform specific policy changes. Many weeks ago, the Alliance of Wound Care Stakeholders made five specific recommendations to Centers for Medicare & Medicaid Services (CMS). These recommendations address several of the problems pertaining to CTPs/skin subs that have been raised in the past series of blogs. Unfortunately, even when good ideas emerge that might fix or improve a problem, CMS can (and often does) ignore them.

Here are the Alliance recommendations to CMS about CTP/skin subs:

  1. Assign the existing add-on codes (15272/C5272to , 15274/C5274, 15276/C5276, and 15278/C5278) for the application of CTPs to appropriate APC groups, and to allow separate payment for the add-on codes.
  2. Assign the application of CTP codes for the same size wound, regardless of anatomical location on the body, to the same APC groups. NOTE: Currently the code for application to a 100 sq cm ulcer on the foot is assigned to the same APC group as 25 sq cm ulcer – even though the PBD must purchase a lot more product. Conversely, the code for the application to the same size 100 sq. cm ulcer on the leg is assigned to a different APC group which aligns with a higher allowable rate to account for the purchase of more product.
  3. Assign all new CTPs (with either “Q” or “A” codes) to the low-cost APC groups until the manufacturer provides cost information to CMS
  4. Assign both the high-cost and lost-cost application codes to higher paying APC groups that reflect the current Average Sales Price of all CTPs. CMS requires manufacturers to submit the average sales prices on a quarterly basis. CMS should use that information to map CTPs with both “Q” and “A” codes to the appropriate high-cost and low-cost groups.
  5. CMS should not assign CTPs that are not in sheet form to any APC group because those products are not covered by Medicare and are not allowed to be reported with the application codes 15271-15278 and C5271-C5278.

If you have other ideas that might address the long list of problems identified so far, feel free to send them to me.