October 25, 2022
The Coalition voiced its concerns with CGS's proposed LCD/LCA on Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers with oral testimony at the Medicare Administrative Contractors' public meeting recommending that CGS withdraw the draft, then work with stakeholders and the CAC to craft a more accurate policy based on the most currently available evidence. The Coalition elevated its concern that CGS issued an LCD/LCA that is verbatim to what was issued by Novitas and First Coast, without doing its own due diligence to evaluate the evidence supporting the policies. The Coalition emphasized its concerns with:
  1. The allowance of only 4 applications of a specific product is an arbitrary application limitation not based on evidence.
  2. The inappropriateness of language in the policy that refers to CTPs as "surgical supplies" - which is clinically incorrect.
  3. The lack of clarity and transparency on the specific evidence required of manufacturers in order for their products to be placed in the Group 2 covered product listing.
  4. The lack of evidence to substantiate the significant changes that CGS is attempting to make. 

See Coalition Testimony
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