Building a Wound Care Practice: Are Cellular Tissue Products Worth Using?
Cellular tissue products have been marketed heavily to podiatrists by biotech firms. Clinical outcomes have been strong — many patients avoid limb loss — and physician income has risen alongside their use. But the reimbursement landscape is more complex than it appears.
Understanding CTP Reimbursement Models
Reimbursement for CTPs depends on two pricing models: Average Sale Price (ASP) or WAC (Wholesale Acquisition Cost)/invoice.
Of 68 available CTPs, Medicare could not calculate ASP for 30 products because manufacturers withheld that data. Those products are reimbursed at a higher rate based on WAC/invoice — costing CMS more and drawing greater scrutiny toward the billing provider.
The OIG Report
A March 2023 OIG report by Anne Maxwell found that Medicare reimbursed:
$256 million+ for WAC/invoice-priced skin substitutes
$132 million for ASP-priced skin substitutes
The gap between these figures highlights the cost disparity — and explains why CMS is paying closer attention to providers who bill for WAC/invoice-priced products.
Key Considerations for Building a Wound Care Practice
Before integrating CTPs into your practice, take a measured approach:
Be realistic in reimbursement expectations: Marketing materials often paint a rosier picture than reality
Do due diligence on companies and products: Not all CTPs are created equal
Do not take company claims at face value: Verify independently
Ask whether CMS bases reimbursement on WAC/invoice vs. ASP: This determines your risk profile
Conduct internal chart audits: Ensure correct documentation for every application
Bill correctly, accounting for waste and proper modifier use: Compliance protects your practice from audits and penalties
The clinical benefits of CTPs are real, but so are the compliance risks. Building a wound care practice requires careful planning, thorough documentation, and a clear-eyed understanding of how reimbursement actually works.