How CTP Regulatory Changes Could Impact Wound Type and Subpopulations

Disclaimer: On December 24, 2025, CMS withdrew the final LCDs for certain skin substitutes. This content was created prior to that announcement and may reference policies that are no longer active. Much of the information remains applicable under other current or future regulations. Always consult your local MAC or payor policies for the most up-to-date guidance.

• CMS (US) — 2026 CTP payment: Hospital outpatient departments and physician offices will be paid similarly; service payment changes minimally, while product payment shifts to a flat ~$127.14 per cm² (with minor geographic variation), replacing packaged pricing in HOPDs.

• No wound-type linkage to price: The flat product price is independent of wound type; wound-type rules apply via LCDs/WISeR, not pricing. Clinicians must select products costing <~$127/cm² to avoid losses.

• Care-setting implications: Reduced margins may challenge home-based care previously supported by higher product profits; however, low-cost products can still yield margins, especially for large wounds, with profit driven by ($127 – acquisition cost) × cm².

Please note: This content is a direct transcript, capturing the authentic conversation without edits. Some language may reflect the flow of live discussion rather than polished text. 

One of the things people are asking is about this big change in the payment model is what wound types will that affect. And I'm going to back up just a second to repeat something that may be obvious to everyone, which is the hospital-based outpatient department and the physician's office are all going to be paid essentially the same way. The actual price for applying the CTP/skin substitute/whatever we're going to call these products, has not changed very much—tiny bit increased for the service itself. It is the way in which the products themselves are being paid that has completely changed. And in the hospital-based outpatient department, it used to be under this thing called package pricing. I think everybody's aware of that, that there was a fixed payment rate for the service and the product that is going away. 
 
In the doctor's office, there was a separate payment for the cost of the product, a highly complicated math. But now what's going to happen is every product, no matter which product you pick, you get paid $127.14-ish—it varies a little bit geographically for the product. So the first thing I want to say about which wounds is, what will change for sure at the very beginning is which products you are picking. And whatever product you pick, you have to pick a product unless you want to lose money that costs less than $127.14-ish for purchasing the product. 
 
So the pricing change did not have any specific connection to the wound types that you're using the product on. So coverage and payment policy happened completely separate from each other. So if our conversation is only around payment policy, then it doesn't have any direct link to any specific wound type. That's what will happen with LCDs or with this WISeR prior authorization model. All of that stuff about wound type happens somewhere else. The price is not related to what wound type you pick. 
 
The next question has to do with whether any certain populations of patients will be impacted more. And if we're still only thinking about pricing, not thinking about covering, not thinking about coverage policy. And that’s a big “if” because so much is linked to the coverage policy. We’re just talking about price. The big impact that many people are worried about, the idea that it is the potential profit for the purchase of the product that has enabled home care to really happen. And the reason was, sadly, just as a sidebar conversation, we pay too little for things that we should pay more money for. It makes it very hard for clinicians to afford to drive potentially long distances to go see a patient in the home. 
 
And one of the strange downstream impacts of the skyrocketing price of the CTPs has been that there was now big enough profit margin to enable physicians to go to the home and make enough profit that they could have that very inefficient—and I don't mean that as a criticism, like having to go drive somewhere as an inefficient model compared to having people come to see you in your office are going bed to bed in a skilled nursing facility. So understandably, if the model of home care was being funded by the profit off skin subs, the patients in the home will be affected by the change in price. And that may be a valuable conversation to have completely separately, but there are just lots of things that were not going well in the home that are being handled through coverage policy. And I don't have an opinion about that. It’s just true that it will be harder for patients to get skin substitutes in the home because if the model that allows the physician the economic ability is that they made a very large profit per square centimeter. It will be hard to continue to fund that. 
 
Now having said that it really is a little bit relevant because there are some low-price products that do involve a fair margin of profit and maybe it’s good for us to go back a step and talk about how this is really going to work. I mentioned the $127 and there have been different prices quoted. They made a correction and it's a little different from one region to the next. But here's what that means. It means that I'm going to, let's say, purchase, need to buy a piece that's a 10 by 10 for a very large wound. Well, the amount of profit that I'm going to make is the difference between $127 and what I buy that piece for. If I can buy that piece for $50, then I will keep $127, less $50 per square centimeter. So very big wounds can be treated, and the profit is the difference between $127 and whatever you purchase the product for. So by using very low-priced products, and there are some very low-priced products with a tremendous amount of data around them, that have a proven track record. It’s still possible for clinicians to make a very good profit for each of those pieces with more profit of course based on the larger size of the wound. So there’s still the possibility of thousands of dollars of profit per patient just depending on the size of the wound and the product you pick. 
 
So I don't want to imply that it's all over. The answer is always “it depends.” And not being someone who sees patients in the home, I don't know what kind of per patient revenue is required to allow a clinician to drive to the home to see someone because I know some people have gone very large distances and that may truncate the model but not end it. So I just don’t want people to think there’s nothing left. That’s not how this is going to work. The difference is the way to do continue to have a good business model for your practices—you’re going to be picking the lowest price product you possibly can and then the difference between that price and $127 is what you’re going to keep times the number of centimeters that you purchase. 

Dr. Fife is the Chief Medical Officer of Intellicure, LLC.