On December 10th, the Medicare Administrative Contactors (MACs) held a virtual Town Hall meeting to discuss Local Coverage Determination (LCD) for Skin Substitutes / Cellular Tissue Products that goes into effect on February 12, 2025. The MAC medical directors spent time clarifying key points in the LCDs, and then practitioners and industry representatives presented questions.
I may post more information about the meeting later, but the general tone of the MAC medical directors was confident. There was no indication that the implementation of the LCDs would be delayed for any reason. My personal opinion is that the LCDs are going into effect, regardless of any legal challenges that might be brewing.
Sales representatives for products not on the list are apparently telling practitioners that the LCD will NOT be implemented. Although I do not have any “inside knowledge,” there is no indication that this is true. I think it is important to let practitioners know that they should plan on becoming compliant with the LCDs by February 12. Becoming compliant means using only the CTPs/skin subs on the approved list when treating DFUs and VLUs AND being compliant with the exhaustive clinical and documentation requirements.
We do not know what the MACs will do about CTP / skin sub claims for other wound types (e.g., pressure ulcers, surgical complications, chronic ulcers, etc.) if the product used to treat those other wound types is not on the “covered” list. At the very least, practitioners should make plans to perform the same level of clinical care and documentation on these wound types that the LCDs require for VLUs and DFUs.
–Caroline
