Statement from the Alliance of Wound Care Stakeholders
Nov. 19, 2024 – The Alliance of Wound Care Stakeholders is pleased that CMS’ Medicare Administrative Contractors (MACs) carefully considered stakeholder recommendations and made substantive changes following input from the wound care community in the recently released final Local Coverage Determinations (LCDs) and accompanying Coding and Billing Articles, “Skin Substitute Grafts/Cellular and Tissue-Based Products (CTPs) for the Treatment of Diabetic Foot Ulcers & Venous Leg Ulcers.” With publication of the final policy by each MAC, the wound care community now has clearer understanding of Medicare coverage for the application of CTP/skin substitute products in treating diabetic foot ulcers (DFU) and venous leg ulcers (VLU). The Alliance and the larger wound care clinical community mobilized together, illustrating the power of tenacious advocacy and a unified voice to positively influence policies so that they reflect quality wound care practice. In a noted change that was in direct alignment with Alliance recommendations, the MACs increased the covered application limit from 4 to 8 in the final policy, now consistent with the supportive clinical evidence, treatment guidelines and current standard of care to promote wound healing. Similarly the "episode of care" treatment duration increased from 12 to 16 weeks.
The Alliance believes these are considerable improvements to the concerning limitations that had been included in the proposed policies issued for comment this past April. Under the finalized LCDs, providers have the application flexibility (supported by sufficient documentation) needed for wound healing and, importantly, Medicare beneficiaries with hard-to-heal DFUs/VLUs can benefit from improved outcomes. Still, additional clarity is needed...
