Throughout the recent talk of the changes Centers for Medicare & Medicaid Services (CMS) have proposed in regards to Cellular Tissue-Based Products (CTP’s), concerns have been raised in the current gaps of education and documentation needs with these products across the nation. In discussions about what CMS is proposing, industry leaders break down why specific training on medical necessity of CTPs is critical in all aspects of the center and how documentation is the root cause of the upcoming changes.
CTPs, or Skin Substitutes as they were known as up until the last changes CMS made in 2020, are not a modern concept, and have been promoting healing since 1500 BC. Yes, they most definitely have come a long way since using the skin of a frog. However, the concept is still the same. Using components found in living skin that can interact with the body’s natural tissue to encourage healing. And this concept has grown significantly, producing a massive volume of CTP’s available today for patient use.
Since there are a sheer amount of CTPs on the market all with strict medical necessity requirements, centers need to take extra precaution when selecting which of these products to order. Within these products there are different categories of CTPs, such as an Allogeneic or a Composite Matrix, just to name a couple, that will affect how the skin substitute will be applied and what kind of coverage it is going to provide the wound. Although deciding which product to choose is not the only consideration when ordering CTPs, the patient's specific needs have to be addressed both clinically and financially. It is essential before ordering any product to understand the reimbursement of the product, and the medical necessity required. “An Approved For Use list is one way to help centers when ordering products,” VP of Center Operations Michael Curran recommends.
The approved product list is not the only advice for centers, focused education on CTPs and why their approved use is needed, and needs to be well understood to avoid negative effects. “The fear has always been the misuse and improper documentation regarding CTPs and medical necessity.” Admits Chief Nursing Officer Christina Le “With the changes being proposed, it seems we aren't the only ones who had the same concerns. You can see that with the new requirements and updates regarding documentation being updated. CMS is requiring several updates in many different areas to ensure that we are providing the entire picture of the patient and assessing all their needs.”
It’s all a result from the tedious documentation protocol of CTPs, “since they are an advanced procedure/product that requires more attention and has additional medical necessity requirements.” Michael Curran explains, and “the proposed changes are only going to make the documentation process have little room for error.”
Training on CTPs needs to be at all levels of the center, from ordering products to patient use, and with the proposed changes, there can be a drastic change on what CTPs are approved. Close attention from all centers should be given when the changes are made, and understand the impact the changes can have on them, especially in this time of review. In the second part of this blog, find out what each proposed change can mean, and what to prepare for.
