Skin Substitute Proposals: What You Can Do

May 29, 2024
Medicare Advantage Plans

On April 25, 2024 all seven Part B MACs released proposed policies that would govern the application of skin substitute grafts/cellular and tissue-based products for the treatment of diabetic foot ulcers and venous leg ulcers for Medicare Part B beneficiaries. The specifics of these proposals have already been covered in this space. There are elements of these proposals that providers and other stakeholders are not pleased with. Fortunately, these proposals are in a comment period until June 8, 2024. Any interested stakeholder may submit comments to share their feedback on these proposals.

Different Part B MACs have jurisdiction over different states / territories. Providers may submit comments to the MAC that has jurisdiction over the state(s) in which they practice. Below is a list of each Part B MAC, the states / territories in their jurisdiction, and where comments on these skin substitute / CTP proposals may be submitted.

Noridian
Noridian Jurisdiction F
(AK, AZ, HI, ID, MT, ND, OR, SD, UT, WA, WY)
Submit comments to:
Noridian Healthcare Solutions, LLC JF Part B Contractor Medical Director(s)
Attention: Draft LCD Comments
PO Box 6781
Fargo, ND 58108-6781
policydraft@noridian.com

Noridian Jurisdiction E
(CA, NV)
Submit comments to:
Noridian Healthcare Solutions, LLC JE Part B Contractor Medical Director(s)
Attention: Draft LCD Comments
PO Box 6781
Fargo, ND 58108-6781
policydraft@noridian.com

First Coast
(FL, PR, VI)
Submit comments to:
Medical Affairs
2020 Technology Parkway
Suite 100
Mechanicsburg, PA 17050
ProposedLCDComments@fcso.com

Novitas
(AR, CO, DE, LA, MD, MS, NJ, NM, OK, PA, TX, Wash DC)
Submit comments to:
Medical Affairs
Suite 100
2020 Technology Parkway
Mechanicsburg, PA 17050
ProposedLCDComments@novitas-solutions.com

Palmetto
(GA, MS, NC, SC, TN, VA, WV)
Submit comments to:
Part A Policy
PO Box 100238 (JM) or PO Box 100305 (JJ)
AG-275
Columbia, SC 29202
A.Policy@PalmettoGBA.com

NGS
(CT, IL, MA, ME, MN, NH, NY, RI, VT, WI)
Submit comments to:
Juan Schaening-Perez, MD
1717 West Broadway
PO Box 1787
Madison, WI 53701-1787
policycomments@wpsic.com

CGS
(KY, OH)
Submit comments to:
Meredith Loveless, MD
Attn: Medical Review
26 Century Blvd., Ste ST610
Nashville, TN 37214-3685
cmd.inquiry@cgsadmin.com

Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC, CPMA

Dr. Lehrman is a Board Certified Podiatrist, Certified Professional Coder, and Certified Professional Medical Auditor. He is in private practice in Colorado and operates Lehrman Consulting, LLC which provides consultation services regarding coding, compliance and documentation.

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