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,...
by Caroline Fife, M.D. | Jun 8, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Check out attorney Knicole Emanuel’s recent blog post, written to wound care practitioners, “Medicare Auditors Are Not Wound Care Specialists: Why Providers Win Appeals When the Full Story Finally Gets Read”! Her post reinforces the reports I am hearing,...
by Caroline Fife, M.D. | May 18, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Last month, Dr. Ryan Mathis updated us on the legal initiative around CAMP (skin sub/CTP) pricing. The case, filed in the district court of the Northern District of Texas, was dismissed — not because the companies lost on the merits, but because the judge said...
by Caroline Fife, M.D. | Apr 24, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Guest Blog by Michael Crouch Dr. Fife – Like you, I follow the blog of well-known healthcare attorney, Knicole Emanuel, and her recent post “The End of Chevron Deference: How Loper Bright Could Help Defendants Challenge Materiality in False Claims Act Cases |...
by Caroline Fife, M.D. | Apr 3, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
In response to the dramatic change in CTP (“skin substitute”) payment methodology, an organization representing many skin substitute manufacturers and distributors sued the Department of Health and Human Services (HHS). Dr. Ryan Mathis, Director of Global Medical...
by Caroline Fife, M.D. | Feb 10, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Medicare audits on CTPs/skin substitutes are ubiquitous and the audits all seem to follow the pattern that Michael Crouch described in his articles The Incredible Journey: Lessons Learned from a “Skin Substitute Graft” Audit – Part One and Here Comes the...
by Caroline Fife, M.D. | Feb 9, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
On Jan. 8, 2026, HMP posted the first part of my interview on the Viewpoints section of “Wounds” (HMP Global Learning Network). This segment is about “The Impact of CTP Changes on Provider Types.” You can access content here: The Impact of CTP Changes on Provider...
by Caroline Fife, M.D. | Feb 4, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes
Dear Manufacturer of Cellular Tissue Product (CTP) Skin Substitutes, In the past few weeks, the CTP/skin sub market has completely changed and the roadmap for the clinical use of your products is completely different. I thought I’d say the quiet part out loud about...
by Caroline Fife, M.D. | Jan 9, 2026 | Cellular / Tissue-Based Products, CTP / Skin Substitutes, Uncategorized
I understand why CMS did it. There has been wild abuse of the Cellular Tissue Product (CTP) / skin substitute wastage code. The payment model incentivized practitioners to use large pieces even on small wounds, because they could get paid for the amount they wasted....
