Part One of My Interview on CTP Changes is Now Available on HMP Global Learning Network/Wounds
On Jan. 8, 2026, HMP posted the first part of my interview on “The Impact of CTP Changes on Provider Types.”
What We Need Next is a ZIP Code Rosetta Stone for Wound Care Outcomes
It is time to use already available ZIP code information to alert healthcare practitioners of community risk factors.
Texas Medical Association (TMA) resources for the new WISeR prior authorization program affecting CTP/skin subs
The Texas Medical Association (TMA) has a new education sheet to guide clinicians through services...
In 2026, Monetary Threshold is Higher for Medicare’s Expedited Access to Judicial Review (EAJR)
I hope those of you who are experts at the appeals process will provide some information in a guest blog about the EAJR process.
Step-by-Step Instructions on How to Download Your Field Test
CMS has posted the Cost Measure Field Test reports on the QPP website! It’s time for you to download yours!
CMS Press Release: Prepare for 2026 Field Testing of Episode-Based Cost Measures
Field Test Reports for eligible clinicians and clinician groups will be available on the Quality Payment Program Portal beginning January 29.
How to Prepare For & Make the Most of Your Field Test – Attend CMS Meetings on Jan 27 and Feb 18
CMS is holding office hours with specialty societies and organizations to provide information about the upcoming field testing period.
Here We Go Again: CMS is Testing a New “Non-Pressure Ulcer” Cost Measure
I will be posting a series of blogs explaining this in more painful detail, including a step by step guide to download your Field Test report.
Noridian Webinar Materials on Wasteful and Inappropriate Service Reduction (WISeR) Model
I attended the Noridian informational call on the Wasteful and Inappropriate Service Reduction (WISeR) model.
Breaking News! Medicare Will Not Pay for CTP / Skin Substitute Wastage “Under Any Circumstances”
Medicare fee for service (FFS) does not pay for discarded amounts of “incident to supplies” (which is how all non-BLA CTPs/skin subs are now classified) and will only pay for the amount of product furnished.
A New Era for Cellular Tissue Products / Skin Substitutes
Price controls are better for patients, Accountable Care Organizations, secondary insurers, tax payers, and the Medicare trust fund.
Breaking news! Cellular Tissue Products (CTPs) / CAMPS to be Paid at $127.28/cm2
Breaking news! Physician fee schedule finalized: CTPs/CAMPS priced at ~$127.28/cm2. Read more...
Check Out the Editorial in Med Page Today: 2 Doctors Concerned About Improper Use of Skin Substitutes
On October 8th, Med Page Today published an opinion piece about the increasing improper use of skin substitutes in chronic wounds.
Pyoderma Gangrenosum Nonprofit Kickoff Meetings “ALL THINGS PG”
There is a new, non-profit Patient and Family Advisory Council for Pyoderma Gangrenosum.
Cellular Tissue Products / Skin Substitute Applications in the Home Setting – Check Out Kathleen Schaum’s Recent Article in Advances in Skin and Wound Care
The application of a Cellular Tissue Product (CTP) / skin substitute, a surgical procedure, is out of the scope of a registered nurse.
Practitioners May Now Review Their 2024 Merit-Based Incentive Payment System (MIPS) Final Scores
To address errors with the 2024 MIPS final scores, CMS says participants have approximately 60 days to request a targeted review.
Check the OIG list of “Excluded Individuals” Before Hiring!
To avoid CMP liability, health care entities should routinely check the list to ensure that new hires and current employees are not on it.
FDA Issues a Letter to Health Care Providers to Follow Instructions for Safe Use of Hyperbaric Oxygen Therapy Devices
These standards are designed to prevent fatal hyperbaric chamber fire and explosion risks in oxygen-enriched, pressurized environments—where even a small spark from an electronic device can be catastrophic.
OIG Calls for Urgent “Skin Substitute” Payment Reform Based on Analysis of Medicare Data
According to the report, in 2024, skin substitutes accounted for over 15% of the $66 billion that Medicare spent on all Part B drugs.
Dear APM Docs: Your 2023 APM Bonus Is Waiting… If CMS Can Find You
You might be participating in an APM and not even know it – that happens a lot – so there’s no harm in updating your payment information.
2024 MIPS Final Scores Won’t Publish Until Fall
Download the 2024 MIPS scoring guide for more information on performance criteria and how final scores are calculated.
CMS Warns of Fraud Scheme Around Medicare Audits
CMS has identified a fraud scheme targeting Medicare providers and suppliers. If you receive a suspicious request, don’t respond.
DEA Warning: Fraudsters Impersonating DEA Officials are Scamming Clinicians
Federal law enforcement officers are prohibited from demanding cash or gift cards from a member of the public.
Hyperbaric Physicians (and Hospital Program Managers): Check the 2023 Medicare Data! Protect Your NPI and Don’t Put Hospital Facility Fees at Risk
Check the 2023 Medicare data! Protect your NPI and don’t put hospital facility fees at risk.
Just Released: Hospital Outpatient Proposed Rule Would “Unbundle” Cellular Tissue Products (CTP) / Skin Substitutes in the HOPD
I will try to post a better analysis of the impact of these proposals in the HOPD (hopefully provided by readers who understand this better than I do).
Show Me the Regulation!
When clinicians or management companies ask why a process must be done in a certain way, they are told, “It’s a regulatory requirement.”
BREAKING: 2026 MPFS Proposed Rule sets single payment for all CTPs at $125.38/cm2
There will no doubt be a significant response from manufacturers and clinicians in response to this proposal.
Scam Alert! CMS Issues Warning on Medicare Audit Phishing Scheme
Increased awareness of the Medicare audit climate could cause clinicians to be fooled by these scams. Watch out!
RFK Jr. and Dr. Oz Pledge to Fix Broken Prior Authorization System
heir commitments reinforce the role of CMS in monitoring outcomes and promoting accountability.
BREAKING NEWS in the DOJ Press Conference! More Skin Substitute / Cellular Tissue Product (CTP) Fraud Indictments
Wound Care, specifically around the use of amniotic “skin substitutes,” made the news in the fraud press release.
Site Neutrality – a Looming Disaster or an Opportunity?
Now may be the time for academic programs and large hospital systems that still provide needed emergency hyperbaric services to start contacting their congressmen.
The Quality Payment Program (QPP) “Doctors and Clinicians Preview Period” for 2023 is Officially Open
Clinicians who reported data as part of the Quality Payment Program (QPP) in 2023 can preview their 2023 performance information before it appears on the Medicare.gov compare tool and in the Provider Data Catalog (PDC).
DOJ Unveils a New Corporate Enforcement & Voluntary Self-Disclosure Policy (CEP)
The Department of Justice’s Criminal Division is “turning a new page on white-collar and corporate enforcement.”
Providers Under Siege
The stakes go beyond money: reputational harm, exclusion from Medicare and Medicaid, and even criminal charges are on the table.
States Try to Limit the Use of AI in Prior Authorization
Read the complete article for more details on what individual states are doing to push back on the use of AI in Prior Authorization.
CTP-related LCDs Postponed at the Last Minute!
The LCDs that will directly impact CTPs (Skin Subs) have been postponed until January 1, 2026! Announcement came at the last minute!
Overzealous Medicare Audits
Be sure to read all of Ms. Emanuel’s article, which calls for radical reforms such as holding auditors accountable for mistakes.
Hospitals & Doctors Spend a Lot of Money Just Trying to Get Paid
No wonder practitioners in private practice have been tempted by the big dollars to be made from skin substitutes.
What Happened to “Innocent Until Proven Guilty? Check Out this Article on Medicare Recoupment
Check out Knicole Emanuel’s recent blog post about CMS monetary recoupment before full adjudication.
Fewer Regulatory Hoops but Continued Scrutiny on Fraud Under the Trump Administration
While the Trump Administration may be reducing the regulatory burden in many areas of government, they are NOT reducing their focus on reducing on fraud investigations.
The Cigna Group Launches Actions to “Drive Positive Change for Customers & Patients”
There are five key areas of focus, and several initial specific actions, to improve the health of its customers and the value it provides.
ACA Healthcare Plan “Just Say No” to 1 in 5 Claims
ACA insurers denied 1 in 5 medical claims in 2023, the highest rate since 2015.
Murphy Introduces Bipartisan Legislation to Preserve Medicare for Patients and Physicians
I worry that the misbehavior of a small percentage of practitioners will reduce enthusiasm for a bill to fix a huge physician reimbursement problem.
A Titanic Shift at CMS: The Push to Trim Administrative Costs & Increase Audits – Knicole Emanuel’s Recent Post
Ms. Emanuel likens CMS to the Titanic in terms of how hard it will be to turn such a massive ship. Let’s hope this story will end differently.
“Defending Against Medicare and Medicaid Audits: A Guide for Healthcare Providers” by Knicole Emanuel
She notes that, “Recent statistics show that CMS, through its contractors, conducted over 300,000 audits in recent years.”
Noridian Surgical Dressings Webinar – 02/11/2025
The Noridian Provider Outreach and Education staff is hosting the Surgical Dressings webinar on 02/11/2025, 12:00 PM – 1:30 PM EST.
Landmark Antitrust Settlement Calls for Blue Cross Blue Shield to Pay $2.8 Billion into a Fund Designated for Physicians and Others
The fund is designated for settlement class members, including physicians, group practices, and health care facilities.
LCDs Delayed Until April 13, 2025
If you scroll to the end of the LCD, it will state the future effective date of 4/13/25.
American Relief Act Extends Some Telehealth Waivers Including Audio-Only Telehealth
The continuation of Medicare telehealth flexibilities follows another recent telemedicine extension by the DEA and the Department of HHS.
BREAKING NEWS: Wound Care Company Owners Plead Guilty to $1.2 B in Fraudulent Claims for Amniotic Products and Face Prison
The case was handled through the Health Care Fraud Strike Force Program, which currently operates in nine Strike Forces across the country.