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Wound Care Articles and Insights
January 7, 2025

New Skin Substitute Policy Signals Major Shift in Wound Care Reimbursement

Chris Schellenbach

SIERRA MADRE, CA — The Centers for Medicare and Medicaid Services (CMS) will be implementing sweeping changes to reimbursement for Cellular and Tissue-Based Products (CTPs), also known as skin substitutes, effective on February 12th, 2025. This unprecedented policy, introduced simultaneously by eight Medicare Administrative Contractors, reflects a significant effort to address misuse and fraud while emphasizing evidence-based care.

“These changes mark a pivotal moment in our industry,” said Mike Comer, CEO and Founder of Wound Care Advantage (WCA). “After 30 years in wound care, I’ve never seen a policy released with this level of coordination. It’s clear Medicare is serious about enforcing proper utilization of these products. Every hospital will need to be meeting these new standards, and we can help with that.”

The new Local Coverage Determination (LCD) will take effect February 12th, 2025,drastically reducing the number of reimbursable products to just a few. It also establishes stringent documentation requirements and utilization limits. The policy permits no more than eight applications over 16 weeks and demands explicit justification for cases exceeding four applications.

WCA has long been a leader in evidence-based wound care, achieving an average healing time of under eight weeks across all wound types with a skin substitute utilization rate of less than 2%.

“These figures demonstrate that exceptional outcomes don’t require excessive CTP use,” Comer added. “We’ve prioritized using the right product at the right time while maintaining compliance and driving exceptional healing rates.”

Christina Le, Chief Nursing Officer at WCA, emphasized the importance of education and preparation. “The new LCD is challenging but manageable with the right tools and knowledge. We’re helping our partners align their documentation and treatment processes to stay compliant while continuing to provide the best care possible.”

To help hospitals and wound centers adapt to these changes, WCA has released a free guide outlining essential next steps. Key recommendations include:

  • Staff Education: Train clinical and billing teams on updated documentation and application limits.
  • Optimized Procurement: Focus inventory on approved products and reduce wastage.
  • Compliance Oversight: Designate a compliance team to audit medical records and claims.

“The OIG has followed up by announcing that they will be taking a closer look at CTP utilization, making it vital to stay compliant” said Comer. “At WCA, we’re here to support wound centers and our partners every step of the way. Utilizing our platform, we  deliver 5 key features that will keep centers compliant with these new changes.”

The 5 Keys to Compliance:

  1. CTP authorization review by experts
  2. CTP policy and procedure review
  3. Regulatory monitoring
  4. Documentation review
  5. Ongoing compliance training and education

To learn more about how our platform drives compliance and for more detailed information on next steps for wound centers, download WCA’s essential guide to the new CMS policies, visit thewca.com/landing-pages/cms-wound-care-compliance

About Wound Care Advantage

For over 20 years WCA has supported a national network of wound centers focused on reducing costs and improving patient outcomes. WCA empowers these centers by seamlessly transitioning from outsourced management to in-house support, leveraging Luvo – the industry's most powerful business intelligence platform. How can WCA support you? Learn more at www.thewca.com.

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