DELAYED IMPLEMENTATION: "future effective date" for CTP (skin substitutes) LCDs is now 4/13/25
1/25/25 - All of the Medicare Administrative Contractors (MACs) have delayed the effective date of the final local coverage determinations for cellular and tissue-based products for wounds (CTPs, or "skin substitutes") in diabetic foot ulcers and venous leg ulcers by 60 days, moving the implementation date across all MAC jurisdictions from 2/12/25 to 4/13/25.
Note: the local coverage determinations themselves are unchanged, only the effective date has postponed.
As there were seismic changes to the number of covered products, allowable applications, and required documentation in the final LCDs published in November 2024, wound care providers across the country who treat DFU/VLU in Medicare beneficiaries have been preparing for the original February 12, 2025 implementation date. This 60 day postponement to April 13th has the upside of providing additional preparation time.See the "Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers & Venous Leg Ulcers" LCDs from each MAC below.
(The new effective date is at the very beginning and end of each LCD.)
- CGS Administrators: Final LCD (L39756); Billing & Coding Article (A59941)
- First Coast Service Options: Final LCD (L36377); Billing & Coding Article (A57680)
- National Government Services: Final LCD (L39828); Billing & Coding Article (A59712)
- Noridian J-E: Final LCD (L39760), Billing & Coding Article (A59626)
- Noridian J-F: Final LCD L39764; Billing & Coding Article (A59628)
- Novitas: Final LCD (L35041); Billing & Coding Article (A54117)
- Palmetto GBA: Final LCD (L39806); Billing & Coding Article (A59691)
- WPS: Final LCD (L39865), Billing & Coding Article (A59740)
Map of A/B MAC jurisdictions.
Look up your A/B MAC by state.
The Alliance of Wound Care Stakeholders has been a vocal and tenacious advocate as these local coverage policies were developed over the past several years. As a unified advocacy voice, we’ve together collaborated on and submitted multiple written comments and oral testimonies on this particular policy and others impacting access to CTPs. See the Alliance's advocacy efforts around coverage and payment of CTPs/skin substitutes.