Skin Substitute Policy Update

All seven Part B MACs have delayed the effective date of their new skin substitute local coverage determinations (LCDs) until April 13 without changing any of the content of those policies.

As previously reported in APMA Weekly Focus, on November 14, 2024, all seven Part B Medicare Contractors released final LCDs that will govern the provision of skin substitute grafts/cellular and tissue-based products to Medicare Part B beneficiaries when used for the treatment of diabetic foot ulcers and venous leg ulcers. These policies were previously scheduled to take effect February 12, 2025.

Following APMA advocacy and APMA's response to the initial proposed version of this policy, there were several improvements in the final version compared to what was initially proposed. Some highlights include:

• The proposed requirement to perform an ankle-brachial index was modified to instead require a "vascular assessment."
• The final policy increased the number of skin substitute graft/CTP applications from four to eight within an episode of skin replacement therapy (defined as 12 to 16 weeks from the first application of a skin substitute graft/CTP) when there is documentation of progression of wound closure under the current treatment plan with documented medical necessity for additional applications.

Read APMA Weekly Focus for further updates.