Wound Care Articles and Insights
June 11, 2024

CMS Reimbursement Update: Wound Care Skin Substitutes Highlights

Mike Comer

The LCD draft discussed in our guide is unprecedented in the wound care industry. Having worked in this field for nearly 30 years, I have never witnessed such a coordinated release of a policy of this nature. The simultaneous release of this LCD by eight Medicare Administrative Contractors signals the significance that Medicare attributes to addressing this issue. I vividly recall the excitement surrounding the initial introduction of skin substitutes into the market. They were widely regarded as a remarkable option for the most stubborn wounds, representing a new tool in our arsenal.

Regrettably, over the past two decades, these innovative advancements have, in many cases, been prone to fraud and abuse due to the potential financial impact on medical practices.

Throughout the last decade, the facilities within the Wound Care Advantage Network have achieved an average healing time of less than 8 weeks across all wound types. The utilization of Cellular Tissue Products (CTPs) or Skin Substitutes in our patient population has remained below 2%. I take pride in these figures as they illustrate our commitment to using the appropriate product for each patient at the right time while demonstrating that exceptional outcomes are not contingent on excessive CTP utilization. For over a decade, Wound Care Advantage (WCA) has supported our programs in this topic through education, data analysis, and our authorization review  teams.

Although this draft policy is not flawless, and could fail due to legal challenges. It clearly indicates CMS's belief that utilization must be more regulated, and demonstrates their proactive approach in addressing the matter. If this policy fails to be implemented, it will likely come back as an NCD. The extensive list of CTPs has been reduced to just 12 products that will be reimbursed by Medicare. Documentation requirements and utilization standards have become significantly more stringent. 

While the WCA team will closely collaborate with our partner facilities to ensure comprehension and compliance with these measures, I strongly urge all members of the industry to invest the time in reading the LCD in its entirety. I recognize that it may appear mundane and uninteresting, but I genuinely believe that CMS's approach represents a pivotal moment for our industry. By downloading our 1 page highlight document, you will be better prepared for future changes.

In times like these, having a partner like Wound Care Advantage becomes not just advantageous, but essential. If recent events have taught us anything, it's that complacency is not an option. If you're feeling the weight of regulatory uncertainty bearing down on your shoulders, don't hesitate to reach out. Let Wound Care Advantage be your partner in navigating the turbulent waters of healthcare regulation. Together, we'll ensure your center not only survives but thrives for years to come. Contact us today to learn more about how we can support you in the face of uncertainty. Because when it comes to regulatory changes, the only certainty is the need for proactive action.

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