Medicare Administrative Contractors Withdraw LCDs/LCAs that Disrupted Care, Dramatically Restricted Access to CTPs (Skin Substitutes)

Following tenacious collaborative advocacy from the Alliance of Wound Care Stakeholders and across the wound care community, three Medicare Administrative Contractors – Novitas, First Coast Service Options, and CGS Administrators – today withdrew their local coverage determinations (LCDs) and local coverage articles (LCAs) that that would have dramatically restricted Medicare patients’ access to cellular and tissue-based products for wounds (CTPs, or "skin substitutes”), advanced wound care treatments that are instrumental to wound healing. The policies were scheduled to go into effect on Oct. 1st but have now been pulled. “This was a collaborative effort across the wound care community and, with the withdrawal of the policies, our advocacy clearly had impact. The real winners here are Medicare beneficiaries with chronic wounds who now won’t face disruptions to care or unnecessary restrictions to treatments that can support wound healing,” said Marcia Nusgart, R.Ph., CEO of the Alliance. 

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Oral Testimony on FCSO/Novitas Public Meetings on Draft LCD/LCA for Skin Substitutes for the Treatment of DFU/VLU

The Alliance made its voice heard to First Coast Service Option and Novitas by providing oral testimony at the Medicare Administrative Contractors' public meetings to collect stakeholder input on their draft LCDsand LCAson Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. One of 15 presenters specifically providing oral comments on these policies, the Alliance reiterated recommendations expressed in its April comments and May comments, and questioned why no inputs had been addressed. "If First Coast and Novitas were interested in further comments, then releasing a draft policy taking into consideration our already provided comments would have been a more useful exercise," the Alliance said, reminding the MACS of the key focus of our previously submitted comments: Many of the statements and limitations in the policy do not have the scientific evidence to support them, arbitrary utilization parameters, and clinically incorrect information in the policies