Bioengineered Skin and Soft Tissue Substitute for Diabetic Neuropathic Foot Ulcers, Vascular Insufficiency Ulcer and Chronic Pressure Non-Healing Wounds
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Medicare-members and related plans covered by Blue Cross NC: medical necessity criteria, covered products, coding, and limitations for bioengineered skin and soft tissue substitutes used to treat diabetic neuropathic foot ulcers, venous (vascular insufficiency) ulcers, and chronic pressure non-healing wounds.
03/30/2026: No changes to policy coverage criteria; policy effective date updated to 4/1/2026 per 60-day notification requirement.
01/05/2026: Newly created policy in absence of current NCD, LCD and LCA.
Coverage Criteria for Bioengineered Skin and Soft Tissue Substitutes
Diabetic Neuropathic Foot Ulcer (DFU)
Covered when ALL of the following are met for Diabetic Neuropathic Foot Ulcers:
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Chronic Venous Insufficiency Ulcer (VLU)
Covered when ALL of the following are met for Chronic Venous Insufficiency Lower Extremity Ulcer (VLU):
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General coverage stance
Covered when ALL general policy requirements are satisfied and the product is among those listed for the indication:
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Billing/claim pairing and coverage mapping
Covered when billed with appropriate application and product codes as specified:
BCBSNC may request medical records to confirm medical necessity.
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The following uses of bioengineered skin and soft tissue substitute products are excluded from coverage and considered investigational or not medically necessary: following Mohs micrographic surgery; surgical repair of hernias or parastomal reinforcement; and use of amniotic/placental‑derived products for musculoskeletal indications (including injections or applications for pain, joint conditions, injuries, or other non‑wound musculoskeletal conditions). All other uses of human amniotic products not listed in this policy are also considered investigational and not medically necessary.
The HCPCS codes identified in Group 4 are expressly non‑covered. Examples listed in the document include, but are not limited to, A2001, A2002, A2004, A2005, A2006, A2007, A2008, A2009, A2010, A2011, A2012, A2013, A2014, A2015, A2016, A2018, A2020, A2021, A2022, A2023, A2024, A2025, A4100, C9358. (See Group 4 table in the policy for the full non‑covered HCPCS/code list.)
Coverage does not include liquid or gel skin substitute products or cellular/tissue‑based products (CTPs) in liquid/gel form. Skin substitute graft/CTP application is not covered when placed on an infected, ischemic, or necrotic wound bed. Repeat applications after an unsuccessful prior application are considered not medically necessary, and excessive product wastage is not acceptable. Additionally, coverage limits include a maximum of 8 applications within a 16‑week episode unless additional applications are justified and approved by Medical Director review.
The issuance of a CPT/HCPCS code or FDA approval for a product or indication does not alone establish medical necessity for BCBSNC members. BCBSNC may still determine a product or service is not medically reasonable and necessary for its members; the payer may request medical records to determine medical necessity. Billing an application procedure code or listing an FDA cleared indication is not sufficient without the required clinical documentation supporting medical necessity.
Coding: Application and Product Codes
| 15271 | Application of skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; first 25 sq cm or less |
| 15272 | Application of skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; first 25 sq cm or less |
| 15273 | Application of skin substitute graft to trunk, arms, legs, total wound surface area greater than or equal to 100 sq cm; first 100 sq cm wound surface area, or 1% of body area of infants and children |
| 15274 | Application of skin substitute graft to trunk, arms, legs, total wound surface area greater than or equal to 100 sq cm; each additional 100 sq cm wound surface area, or part thereof |
| 15275 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area up to100 sq cm; first 25 sq cm or less |
| 15276 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area up to100 sq cm; each additional 25 sq cm wound surface area, or part thereof |
| 15277 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area greater than or equal to 100 sq cm; first 100 sq cm wound surface area, or 1% of body area of infants and children |
| 15278 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area greater than or equal to 100 sq cm; each additional 100 sq cm wound surface area, or part thereof |
| C5271 | Application of low-cost skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; first 25 sq cm or less wound surface area |
| C5272 | Application of low-cost skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; each additional 25 sq cm wound surface area, or part thereof |
| Q4159 | AFFINITY |
| Q4128 | ALLOPATCH HD® or FLEX HD |
| Q4151 | AMNIOBAND® MEMBRANE OR GUARDIAN |
| Q4101 | APLIGRAF® |
| Q4122 | DERMACELL® |
| Q4203 | DERMA-GIDE® |
| Q4182 | DERMAGRAFT® (now known TranCyte) (Q4106) |
| Q4187 | EPICORD® |
| Q4186 | EPIFIX® |
| Q4133 | GRAFIX PRIME, GRAFIX PL PRIME, STRAVIX AND STRAVIXPL |
| 15271 | Application of skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; first 25 sq cm or less wound surface area. |
| 15272 | Application of skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; first 25 sq cm or less wound surface area. |
| 15273 | Application of skin substitute graft to trunk, arms, legs, total wound surface area greater than or equal to 100 sq cm; first 100 sq cm wound surface area, or 1% of body area of infants and children. |
| 15274 | Application of skin substitute graft to trunk, arms, legs, total wound surface area greater than or equal to 100 sq cm; each additional 100 sq cm wound surface area, or part thereof. |
| 15275 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area up to 100 sq cm; first 25 sq cm or less wound surface area. |
| 15276 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area up to 100 sq cm; each additional 25 sq cm wound surface area, or part thereof. |
| 15277 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area greater than or equal to 100 sq cm; first 100 sq cm wound surface area, or 1% of body area of infants and children. |
| 15278 | Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area greater than or equal to 100 sq cm; each additional 100 sq cm wound surface area, or part thereof. |
| C5271 | Application of low-cost skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; first 25 sq cm or less wound surface area. |
| C5272 | Application of low-cost skin substitute graft to trunk, arms, legs, total wound surface area up to 100 sq cm; each additional 25 sq cm wound surface area, or part thereof. |
| A2019 | Kerecis Omega3 MariGen Shield, per square centimeter. |
| Q4105 | Integra Dermal Regeneration Template (DRT) or Integra Omnigraft Dermal Regeneration Matrix, per square centimeter. |
| Q4107 | GraftJacket, per square centimeter. |
| Q4110 | Primatrix, per square centimeter. |
| Q4121 | Theraskin, per square centimeter. |
| Q4122 | Dermacell, Dermacell AWM, or Dermacell AWM Porous, per square centimeter. |
| Q4128 | Flex hd, or allopatch hd, per square centimeter. |
| Q4133 | Grafix Prime, GrafixPL Prime, Stravix, and StravixPL, per square centimeter. |
| Q4158 | Kerecis Omega3, per square centimeter. |
| Q4159 | Affinity, per square centimeter. |
| A2001 | INNOVAMATRIX AC, per square centimeter (listed as non-covered). |
| A2002 | MIRRAGEN ADVANCED WOUND MATRIX, per square centimeter (listed as non-covered). |
| A2004 | XCELLISTEM, 1 MG (listed as non-covered). |
| A2005 | MICROLYTE MATRIX, per square centimeter (listed as non-covered). |
| A2006 | NOVOSORB SYNPATH DERMAL MATRIX, per square centimeter (listed as non-covered). |
| A2007 | RESTRATA, per square centimeter (listed as non-covered). |
| A2008 | THERAGENESIS, per square centimeter (listed as non-covered). |
| C9358 | DERMAL SUBSTITUTE, NATIVE, NON-DENATURED COLLAGEN, FETAL BOVINE ORIGIN (SURGIMEND COLLAGEN MATRIX), per 0.5 square centimeters (listed as non-covered). |
| C9360 | DERMAL SUBSTITUTE, NATIVE, NON-DENATURED COLLAGEN, NEONATAL BOVINE ORIGIN (SURGIMEND COLLAGEN MATRIX), per 0.5 square centimeters (listed as non-covered). |
| C9363 | SKIN SUBSTITUTE, INTEGRA MESHED BILAYER WOUND MATRIX, per square centimeter (listed as non-covered). |
Provider Actions, Documentation, and Billing Requirements
Document medical necessity and applicable CPT/HCPCS codes (code inclusion ≠ coverage)
Coverage is provided only when the medical necessity criteria in this policy are met and the listed CPT/HCPCS application and product codes apply; inclusion of a CPT/HCPCS code in the document does not guarantee coverage or reimbursement — the member’s Evidence of Coverage (EOC) governs final benefit determination.
- Policy: “Coverage will be provided… when the medical criteria and guidelines shown below are met.”
- Special note: “The issuance of a CPT/HCPCS code or FDA approval… does not mean that a product or service is medically reasonable and necessary.”
Pair application procedure codes with appropriate product HCPCS on same claim
A Group 1 CPT/HCPCS application code must be billed on the same claim with the appropriate skin substitute product HCPCS code (Group 2 for DFU items or Group 3 as required); failure to pair application and product codes at claim level may affect coverage.
- Prior authorization/claim requirement: “A CPT/HCPCS application code from Group 1 must be reported on the claim and paired with the appropriate HCPCS product code from Group 2 (DFU-only items) or Group 3 as required.”
- Special note requiring same-claim billing: “Billing for skin substitute application procedures is required to also include the appropriate high cost or low-cost skin substitute products.”
Document SOC trial and ≥50% ulcer-area failure for DFU/VLU before substitute
Before using a skin substitute for DFU or VLU, document failure to achieve at least 50% ulcer area reduction after a minimum of 4 weeks of documented standard of care (SOC) including offloading/compression, infection control, debridement, and other SOC elements.
- SOC requirement: “Failure to achieve at least 50% ulcer area reduction with a minimum of 4 weeks of documented compliance with standard of care (SOC) treatment…”
- SOC elements listed: offloading, infection control, limb elevation, debridement, management of systemic disease and medications, nutrition assessment, perfusion assessment, education, appropriate dressings.
Provider action (reserved)
(Reserved)
Ensure complete medical-record documentation for medical necessity determinations
Medical record must document prior interventions that failed, an updated medication history, management of systemic disease (e.g., diabetes, venous insufficiency), planned skin substitute choice with rationale, discussion of procedure risks/complications, smoking status and counseling, wound characteristics, and an ongoing treatment plan including debridement and offloading/compression as appropriate.
- Required elements: failed prior interventions; updated medication history; documentation that patient is under care for systemic disease causing the wound.
- Planned use: explanation of planned skin substitute graft/CTP choice and review of procedure risks and complications.
Include the appropriate product HCPCS code on the same claim as the application procedure
When billing application procedures, include the associated high-cost or low-cost skin substitute product HCPCS code on the same claim; BCBSNC may request medical records and letters of support but these are not sufficient unless the record includes all information needed for medical necessity determination.
- Billing linkage: “Billing for skin substitute application procedures is required to also include the appropriate high cost or low-cost skin substitute products.”
- Records: “BCBSNC may request medical records… letters of support… are not sufficient unless all specific information needed to make a medical necessity determination is included.”
Common denial triggers: application limits, infection/ischemia/necrosis, liquid/gel products, excessive frequency/wastage
Common claim or coverage denial triggers include more than eight applications within a 16-week episode, use on infected/ischemic/necrotic wound beds, use of liquid or gel products, excessive wastage, repeat application after an unsuccessful prior application, or otherwise excessive frequency of applications.
- Application limit: “Greater than eight (8) applications… within… sixteen (16) weeks” may be denied (exceptions require Medical Director review).
- Not allowable: placement on infected, ischemic, or necrotic wound bed; all liquid or gel skin substitute products; repeat application after unsuccessful prior application; excessive wastage.
Omit product code on same claim risks denial and record requests
Failure to report the appropriate high-cost or low-cost skin substitute product HCPCS code on the same claim as the application procedure may result in denial; BCBSNC may request medical records to determine medical necessity when codes/claims do not demonstrate required information.
- Denial risk: “Failure to include the appropriate high-cost or low-cost skin substitute product codes on the same claim as the application procedure may risk denial.”
- BCBSNC may request medical records to confirm medical necessity and claim-level pairing.
Background
Bioengineered skin and soft tissue substitutes (acellular or cellular) are designed to provide a biologic scaffold and, for some products, viable cells to support and promote wound healing in chronic lower‑extremity wounds. These products are intended as adjuncts when standard of care measures have failed and may supply extracellular matrix components, growth factors, or living cells to facilitate granulation and re‑epithelialization. Indicated uses in this policy are limited to diabetic neuropathic foot ulcers (DFU), venous (vascular insufficiency) lower‑extremity ulcers (VLU), and chronic pressure non‑healing wounds, and product selection varies by source, composition, preparation, and regulatory status.
Definitions
Revision History
Policy effective date updated to 2026-04-01 per 60-day notification requirement; no changes to coverage criteria.
Policy newly created in the absence of current NCD, LCD and LCA; notification provided 2026-01-30 for effective date 2026-05-01.
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