Skin Substitute Policies Effective Date Delayed

APMA previously shared that the Novitas, First Coast, and CGS Part B MACs finalized new skin substitute policies for the treatment of diabetic foot ulcers and venous leg ulcers that would go into effect on September 17. All three of these policies state “greater than four applications of a skin substitute graft or CTP within the episode of skin replacement surgery (defined as 12 weeks from the first application of a skin substitute graft or CTP)” are “not medically reasonable and necessary.”

When these changes were initially proposed in 2022, APMA submitted comments and participated in meetings to provide feedback and contest these proposals. APMA also submitted letters to all three MACs contesting the finalization of these policies when they were released last month.

The new effective date for the policies is October 1. All three MACs state the delay to the effective date is due to “a large system update.”

Novitas policy: https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdId=35041&ver=120

CGS policy: https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdId=36690&ver=42

First Coast policy: https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdId=36377&ver=11