The Devil is in the (Contractual) Details: Avoiding Potential Kickbacks in the World of Skin Substitutes (Guest Blog by David Traskey)

The Devil is in the (Contractual) Details: Avoiding Potential Kickbacks in the World of Skin Substitutes (Guest Blog by David Traskey)

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...
Just Released: Hospital Outpatient Proposed Rule Would “Unbundle” Cellular Tissue Products (CTP) / Skin Substitutes in the HOPD

Just Released: Hospital Outpatient Proposed Rule Would “Unbundle” Cellular Tissue Products (CTP) / Skin Substitutes in the HOPD

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...
Just Released: Hospital Outpatient Proposed Rule Would “Unbundle” Cellular Tissue Products (CTP) / Skin Substitutes in the HOPD

CMS Prepares to Launch a Prior Authorization Model for “Skin Substitutes” in Traditional Medicare as Part of the WISeR Initiative

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...