A Simple Step to Save Skin Substitute Services

Currently proposed policies will, if finalized, limit skin substitute application to two applications within an episode of skin replacement surgery for wound care. Those proposing these policies are seeking comments on these proposals before they are finalized.  Anyone reading this can contest these proposals by submitting comments explaining how these proposals are not consistent with peer-reviewed literature and can lead to patient harm and poor outcomes. One can submit comments may by simply sending an email.

These proposals come from Novitas Solutions Inc., a Part B Medicare Administrative Contractor (MAC) with jurisdiction over 11 states and Washington, DC, and First Coast Services Options, Inc., a Part B MAC with jurisdiction over Florida and two US territories. While these policies would only affect the geographic areas under the jurisdiction of these Contractors, it is suggested that all providers and patient advocates in all areas of the country should be concerned because if these policies are finalized, other Medicare Part B Contractors and other third-party payers could attempt to implement similar policies.

Submission of comments is open now and closes May 28.

Comments may be submitted to First Coast here:

Medical Affairs
2020 Technology Parkway
Suite 100
Mechanicsburg, PA 17050
ProposedLCDComments@fcso.com

Comments may be submitted to Novitas here:

Medical Affairs
Suite 100
2020 Technology Parkway
Mechanicsburg, PA 17050
ProposedLCDComments@novitas-solutions.com

It is OK to submit the same comments to both Contractors if you wish to.

First Coast Proposed Policy:  https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdid=39286&ver=7&stateRegion=s12&contractorNumber=368%7C1&proposedStatus=C&sortBy=title&bc=11

Novitas Proposed Policy: https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdid=39285&ver=7&contractorName=6&contractorNumber=all&updatePeriod=985&sortBy=updated&bc=13

Dr. Lehrman operates Lehrman Consulting, LLC and is a Certified Professional Coder and Certified Professional Medical Auditor. Follow him on Twitter @DrLehrman