by Caroline Fife, M.D. | Sep 26, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
For the past 3 years I have been watching the “skin substitute” industry and asking what I thought were simple questions about pricing, payments, and the legality of things like “selling the spread.” I have been worried about the possibility that unwary...
by Caroline Fife, M.D. | Sep 15, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
The Office of the Inspector General (OIG) has just released a report on Medicare claims for “Skin Substitutes”. OIG analyzed Medicare Part B claims data, Medicare Advantage claims data, and manufacturer-reported sales data for skin substitutes in 2023 and 2024....
by Caroline Fife, M.D. | Sep 12, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Dr. Fife, I wanted to provide some follow up on the “Tale of Two Wounds”. Eventually, Wound #1 cost Medicare (and the taxpayer) almost half a million dollars whereas Wound #2 cost less than 1% of that. And since the patient is responsible for 20% of those Medicare...
by Caroline Fife, M.D. | Sep 8, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Dr. Fife, Your articles on skin subs are so helpful. An old coworker of mine called to ask me about the wound care Nurse Practitioner jobs she had seen advertised about applying skin subs. The company did a video interview with her, telling her how much money she...
by Caroline Fife, M.D. | Aug 20, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitute Arrests, CTP / Skin Substitutes
I recently reviewed with interest the press releases and case summaries issued by the Department of Justice (DOJ) related to individuals charged in the 2025 National Health Care Fraud Takedown for their involvement in the “skin substitutes” space.““` With...
by Caroline Fife, M.D. | Aug 12, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Attorney Knicole Emanuel’s most recent blog post is about Medicare audits focused on the use of “skin substitutes” by Recovery Audit Contractors (RACs) and Unified Program Integrity Contractors (UPICs). The proposed skin substitute LCD(s) may be on hold, but that has...
by Caroline Fife, M.D. | Jul 25, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
I appreciate everyone who has emailed and messaged me their questions about the proposed rules for hospital outpatient departments and doctors’ offices! I have invited real experts in coding and reimbursement to provide guest but in the meantime, I will provide the...
by Caroline Fife, M.D. | Jul 23, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
I am noticing how often Nurse Practitioners are being indicted for healthcare fraud. It is partly due to the fact that a very large portion of the CTP/CAMP use is being billed by nurse practitioners. However, it is also due to the nature of the agreements they’ve...
by Caroline Fife, M.D. | Jul 17, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
The proposed rule for Hospital Outpatient Prospective Payment System (HOPPS) has been posted. Like all of the proposed payment policies, it’s massive and you need to read it yourself. CMS is proposing to “unbundle” “skin-substitutes” in the hospital outpatient...
by Caroline Fife, M.D. | Jul 15, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
CMS has released the proposed CY 2026 Physician Fee Schedule. CMS is proposing to continue to pay for CTPs that have a biologic license agreement (BLA) using ASP +6%. However, all other products would be paid at $125.38/cm2 (prior to the application of the geographic...
