by Caroline Fife, M.D. | Aug 20, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitute Arrests, CTP / Skin Substitutes
The Department of Justice (DOJ) announced an indictment of a Nevada wound care physician for fraud in relation to expensive amniotic allografts. (Note that the conduct described below is alleged. Criminal charges are accusations, not findings of guilt.) The...
by Caroline Fife, M.D. | Aug 10, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
In October 2025, Michael Crouch posted a guest blog about a Medicare audit of skin substitute/CTP claims outlining some very interesting reasons for the denial of charges, including: The products used are amniotic membrane allografts. The amniotic membrane acts as a...
by Caroline Fife, M.D. | Jul 31, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
As Michael Crouch detailed in his 3-part guest blog, Medicare providers under audit may face a lengthy administrative appeals process before obtaining a hearing or review by an Administrative Law Judge (ALJ): The Incredible Journey: Lessons Learned from a “Skin...
by Caroline Fife, M.D. | Jul 29, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Subscribers to CMS (Centers for Medicare and Medicaid Services) listservs recently got a very short email announcing that CMS is reopening the call for clinical evidence on skin substitutes. I’d provide a link to the bulletin – but there isn’t one! It was simply...
by Caroline Fife, M.D. | Jul 20, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
The Subcommittee on Health Care and Financial Services Chairman Glenn Grothman (R-Wis.) announced a roundtable on “Medicare Fraud: Examining the Explosive Growth in Skin Substitute Spending”. DATE: Tuesday, July 21, 2026 TIME: 2:00p.m. ET LOCATION: 2154 Rayburn...
by Caroline Fife, M.D. | Jul 15, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitute Arrests, CTP / Skin Substitutes
Since 2022, federal prosecutors have brought an escalating wave of civil and criminal actions targeting skin substitute (cellular and/or tissue-based product, or “CTP”) billing — from single-clinic settlements to the billion-dollar amniotic allograft...
by Caroline Fife, M.D. | Jul 7, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
–The legal fight over how Medicare pays for skin substitutes is back in court! Here’s a guest blog by Dr. Ryan Mathis to explain it. Caroline On June 22, 2026, the CAMPs Initiative refiled its lawsuit challenging the skin substitute reimbursement provisions of...
by Caroline Fife, M.D. | Jul 6, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Just in time for the 4th of July holiday! CMS just released the Hospital Outpatient Prospective Payment proposed rule! There was no change to the skin subsitute payment rate in OPPS. The Physician Fee Schedule proposed rule will be out shortly, but CMS already seems...
by Caroline Fife, M.D. | Jun 15, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Dr. Fife – It has recently come to my attention that several hospitals, physicians, and qualified healthcare professionals continue to report modifiers JZ and JW for the application of non‑BLA (Biologics License Application) skin substitute grafts, also referred to as...
by Caroline Fife, M.D. | Jun 12, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Hi Dr. Fife – I just finished reading your blog on whether audit activity will decline now that overall expenses have come down. It’s an interesting question and, on the surface, a reasonable assumption. In practice, though, the financial return is simply too strong,...
