There are two current proposals that pose a significant threat to skin substitute services. It is important that providers who treat chronic wounds have advanced treatment options available to provide to their patients.
Novitas and First Coast
Novitas Solutions, Inc is the Part B Medicare Administrative Contractor (MAC) for CO, NM, OK, TX, AR, LA, MS, DE, Wash DC, MD, NJ, and PA. First Coast Services Options, Inc is the Part B Medicare Administrative Contractor for FL, Puerto Rico, and the Virgin Islands. Currently these two Part B MACs allow a total of 10 skin substitute applications within a 12 week episode of care. Both have proposed to limit the total number of applications allowed to two. These proposals were released on April 14, 2022 and their comment periods closed on May 28. A final policy is expected to be released soon.
All of Medicare
The 2023 Medicare Physician Fee Schedule Proposed Rule contains proposals regarding the payment of skin substitute services. The full Proposed Rule can be found at https://www.federalregister.gov/documents/2022/07/29/2022-14562/medicare-and-medicaid-programs-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other or downloaded at https://public-inspection.federalregister.gov/2022-14562.pdf
The skin substitute proposals start on page 413 of the Rule and run through page 421 in Section J. These proposals, if finalized, would take effect 1-1-24. In the Rule, Medicare is proposing to bundle the payments for skin substitute application and skin substitute products in the office setting, treating the skin substitute as “incident to” the application. If this proposal were to be is finalized, providers would no longer submit coding for both the skin substitute application and the product in the office setting. Instead, one code would represent both. This would also include the discontinuation of all skin substitute Q codes as they would no longer be needed.
With these threats to skin substitute services, dispensing collagen is an attractive alternative. Collagen attracts fibroblasts to a wound site and supports new blood vessel formation, granulation tissue formation, and epithelialization. Those who dispense collagen also enjoy the profits associated with the surgical dressing program.
Dr. Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC, CPMA
Dr. Lehrman is a podiatrist practicing in Fort Collins, CO and operates Lehrman Consulting, LLC which provides consultation services regarding coding, compliance and documentation. Dr. Lehrman is a Certified Professional Coder and Certified Professional Medical Auditor. He serves as a staff liaison at the AMA CPT® Editorial Panel meetings where CPT codes are created, edited, and deleted. He is a Diplomate of the American Board of Foot and Ankle Surgery, Fellow of the American Society of Podiatric Surgeons, and is recognized as a “Master” by the American Professional Wound Care Association. Dr Lehrman is a Fellow of the American Academy of Podiatric Practice Management, Past Director of the American Professional Wound Care Association Board of Directors, and is a Past Chairman of the Board of the American Society of Podiatric Surgeons. Dr. Lehrman is also on the editorial advisory board of the journal WOUNDS.