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...
by Caroline Fife, M.D. | Jul 11, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Summary of the WISeR (Wasteful and Inappropriate Service Reduction) Model for Medicare (The summary below is partially excerpted from a more detailed review by Julie Rhodovi) Federal Register CMS Page and CMMI Page Model Original Medicare’s fee-for-service payment...
by Caroline Fife, M.D. | Jul 1, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitute Arrests, CTP / Skin Substitutes
In yesterday’s press release, the specific mention of the abuse of “skin grafts” (sic) is from minutes 4:50 to 5:31 Excerpt from remarks by Matthew Galeotti, Head of the Department of Justice (DOJ) Criminal Division, June 30, 2025: “Many of the defendants charged as...
by Caroline Fife, M.D. | Jun 30, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitute Arrests, CTP / Skin Substitutes
Today the Department of Justice (DOJ) held a press conference which was led by Dr. Mehmet Oz, the Administrator of the Centers for Medicare and Medicaid (CMS) and officials from the DOJ, announcing the results of its 2025 National Health Care Fraud Takedown. The...
by Caroline Fife, M.D. | Jun 27, 2025 | Cellular / Tissue-Based Products, CTP / Skin Substitute Arrests, CTP / Skin Substitutes
The Houston Chronicle has reported that a Houston podiatrist and his business partner have been charged with $45 million in healthcare fraud in relation to the billing of bioengineered skin substitutes Dr. David Jenson and Nestor Refael Romero Magallanes are...
