August 30, 2023
Submitted “Request for Immediate Response” letters to Novitas, FCSO & CGS medical directors regarding their LCDs/LCAs on CTPs (skin substitutes) for the treatment of diabetic foot ulcers/venous leg ulcers that were issued as final with substantive new provisions that were not contained in the draft issued for comment, that failed to reflect stakeholder comments, and that contained arbitrary utilization parameters and other restrictive provisions that created significant barriers to quality patient care. The letters flagged numberous clinical issues and procedural process concerns as well as included a detailed collection of Alliance members’ clinical and operational questions in need of clarity.

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