A lot is being said about the way that the new LCD(s) around Cellular Tissue Products (CTPs) / skin substitutes might impact access to care. A big issue is around product choice and ensuring that there is a large enough suite of covered products from which physicians can chose, but I think I will address that after we get more information about how new products will be added to the policies.
What I would like to comment about now is perhaps the most important issue about access to care – cost. I have blogged about this before. In the doctor’s office, the patient’s copay includes the cost of purchasing the CTP/skin sub/CAMP. Since the patient is responsible for 20% of product “cost”, then the best way to improve access to care would seem to be for doctors to use less expensive products. Instead, for reasons discussed extensively already, the most expensive products are the ones being used in the doctor’s office. Among the products marketed by the “established” CTPs/skin sub manufacturers, the average ASP is $134.68. However, among the groups marketed almost exclusively in the “non-package price” environment, the average ASP is $1,013.49. (These far more expensive products provide no additional clinical benefit, and in fact, cannot be justified in any economic sense).
There is a disparity in access to skin subs right NOW because only rich patients and patients with secondary insurance can afford to get a CTP/skin sub. I know it is true because I have posted many marketing materials from skin sub sales reps which specify that their product is for, “Medicare FFS (fee for service) patients only.” Only relatively well-off patients can afford a secondary insurance policy and only wealthy patients can pay tens of thousands of dollars per application if they do not have a secondary policy.
I did have some interesting comments on my blog when I asked why more patients were not up in arms about the cost of copays. One doctor messaged me that his use of very high-priced CTPs did not disadvantage any patients because he “waived the copay.” He could afford to do that because he was making so much profit on the purchase of the product. However, waiving the copays for skin subs has already caused one doctor to settle with the DOJ.
Unless a doctor is improperly waiving copays, there IS a disparity in who gets treated with skin subs right now, and it’s possible that the LCD(s) will improve the problems with access caused by the preference for high priced products.
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.
