Yesterday morning, 8 MACs issued nearly identical draft coverage policies for the use of CTPs (“skin subs”) in diabetic foot ulcers and venous leg ulcers. (Note that the policy does not apply to pressure ulcers/injuries). In addition to the exhaustive documentation requirements pertaining to conservative care and it’s failure (pay attention here, because there are some very subtle requirements that I will blog about later), the draft policies specify a limit of 4 applications (specifically applied over a 12 week period) per calendar year.

The comment period is open, so it’s true that these policies could change. However, as you know, 3 MACs had to withdraw similar language last year after a storm of protest. Now 8 MACs have issued almost identical language. What that tells me is that they will not back down on limiting the number of applications to VLUs and DFUs to 4 per year.

Given what we are learning about the overuse and abuse of these products in the office-based and home setting – does anyone think that the MACs would do nothing? We haven’t offered any better ideas, so the MACs have used the tool they have – limiting access across the board. If adopted, the policies will not go into effect until 2025.

There are a LOT of important details. I will post a series of blogs about those details, but I suggest everyone read these carefully: