SKIN SUBSTITUTES & SOFT TISSUE GRAFTS
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Defines coverage criteria, limitations, and coding requirements for skin substitutes and soft tissue graft products used by Priority Health members; applies to providers submitting claims for these products.
No material clinical or coverage changes in this revision.
Coverage Criteria and Medical Necessity
General Medical Necessity Requirements
Covered when ALL of the following general requirements are met
Breast Reconstruction
Breast reconstruction — Covered when ONE or more criteria are met (AND general requirements)
Burns
Burn-related indications — Covered when general burn prerequisites plus indication-specific criteria are met
Diabetic Foot Ulcers (DFU) and Venous Leg Ulcers (VLU)
Chronic lower-extremity ulcers (DFU & VLU) — Covered when ALL of the following are met
General medical necessity criteria (chronic lower-extremity ulcers)
Covered when ALL of the following are met for chronic lower-extremity ulcers (DFU or VLU):
DFU-specific medical necessity criteria
DFU-specific Covered when ALL of the following apply (in addition to general criteria C.1):
VLU-specific medical necessity criteria
VLU-specific Covered when ALL of the following apply (in addition to general criteria C.1):
Product-specific utilization limits
Product-specific utilization rules (apply when medical necessity met):
General medical necessity criteria
Covered when ALL of the following are met (general approach reflected in document):
Evidence-linked product considerations
Product-specific supportive evidence examples (informational; not an exhaustive approval list):
Zelen et al., 2018
Tettelbach et al., 2019
Burn-specific criteria
Burn care coverage context (adjunctive/conditional use):
Breast reconstruction guidance
Breast reconstruction (ADM) stance:
General adjunctive coverage criteria
Adjunctive use supported when ALL of the following are met:
Product-specific evidence (informational)
Product-specific evidence (informational) — examples cited in the policy:
Zelen et al., 2018
Tettelbach et al., 2019
DiDomenico et al., 2018
Regulatory listings (informational)
Regulatory listings (informational) — FDA product identifiers and device associations are provided for reference and verification
Regulatory identifiers (informational)
Regulatory listings and product associations; no coverage decision criteria provided in these chunks.
Not Medically Necessary — general rule
General policy stance for exclusions and medical necessity
Not Separately Payable / Add-on items
Not Separately Payable / Add-on items
Medical necessity review
Medical necessity review — prior authorization and individual case review processes
General medical necessity
General medical necessity — coverage determinations and plan-level applicability
Investigational/Unproven therapy exception criteria
Investigational/Unproven therapy exception criteria — narrow, exceptional allowances
Acellular dermal matrices (ADMs) are recognized as adjunctive soft‑tissue support in implant‑based breast reconstruction and are not intended as standalone reconstructive materials. Use of ADMs as primary reconstructive materials, as load‑bearing structural components, or for purely cosmetic, prophylactic, or preference‑based enhancements does not meet medical necessity and is excluded. Routine, cosmetic‑only applications and investigational uses (including use under an IDE) are also explicitly not medically necessary.
Skin substitutes and ADMs are considered experimental, investigational, or unproven when applied to superficial or partial‑thickness burns that are expected to heal with conventional wound management. Inclusion of a product on a listing or table does not itself establish medical necessity; substitutes meet medical necessity for burns only when used for dermal replacement, reinforcement, or temporary coverage consistent with a qualifying burn indication.
The policy excludes prophylactic application (including application to closed or epithelialized ulcers) and use on ulcers that are infected, ischemic, necrotic, or gangrenous until those conditions are adequately treated. Skin substitutes should not be used in place of required foundational therapies (for example, revascularization for primarily ischemic wounds or sustained compression for VLUs) and multiple concurrent or sequential products for the same ulcer require documented clinical rationale to be considered.
OrCel™ (reported in this policy mapping as C9399) is medically necessary only within its FDA‑approved humanitarian device indication — specifically, for wounds or donor sites created after surgical release of mitten‑hand deformities in RDEB. Use of OrCel™ outside that humanitarian indication is considered experimental/investigational/unproven and is excluded.
There is no single FDA regulatory category labeled 'skin substitutes'; products in this clinical class enter the market through differing regulatory pathways (PMA, 510(k), HCT/P, etc.). Lack of FDA clearance/approval for a specific indication or use may affect coverage determinations and products must be used consistent with their regulatory status.
Skin substitutes and CTPs are adjunctive treatments and should not replace foundational etiology‑specific care. For example, venous leg ulcers require sustained therapeutic compression as first‑line therapy; skin substitutes are considered only when compression and other standard venous care have been optimized and documented.
Sections that list FDA identifiers, device names, and clearance dates provide regulatory reference only and do not by themselves state coverage exclusions or alter the medical necessity rules elsewhere in the policy.
Similarly, regulatory listings elsewhere in the document enumerate product names and FDA identifiers but do not include explicit coverage determinations or not‑medically‑necessary declarations within those listing segments.
Additional regulatory listing chunks present FDA product/clearance identifiers and product associations; these chunks provide informational regulatory mapping but do not state coverage exclusions or authorization rules.
Regulatory identifiers (510(k)/PMA/HCT‑P numbers) and associated product names are included in this section for reference; the entries are informational and do not themselves specify medical necessity or exclusions.
Additional regulatory product listings repeat FDA identifiers and product names. These entries serve as regulatory references and do not convey coverage decisions or explicit exclusions within the listing text.
This segment lists further FDA 510(k)/PMA identifiers and product names (e.g., Kerecis entries, Matristem, Mirragen) as regulatory reference. No coverage rules or exclusions are specified within these regulatory product lists.
The policy contains an extensive list of specific products and HCPCS/Q/A‑series codes that are designated as not separately payable or as add‑on items to be reported with a primary procedure rather than billed as standalone services. Many named products and A‑ or Q‑codes are explicitly mapped to this not‑separately‑payable/add‑on designation.
A broad set of named skin substitute and soft‑tissue graft products in the exclusions section are mapped to Q‑codes and are listed as add‑on items or otherwise excluded from separate reimbursement. Injectable, flowable, or particulate formulations are specifically noted for some products and affect billing designation.
The exclusions include an extensive enumeration of Q‑codes and HCPCS C‑codes (and many A‑series entries) that are designated as add‑on, not separately payable, or otherwise excluded from separate payment. Examples include numerous Q4xxx entries and the C9352–C9364 group of collagen/nerve/scaffold C‑codes.
Treatments and products determined to be experimental, investigational, or unproven are generally excluded from coverage. Requests to consider such therapies require prior plan approval and review by a Priority Health medical director or clinical pharmacist; exceptions are limited (for example, terminal or severely deteriorating conditions) and require individual case review.
Routine or cosmetic‑only uses, investigational applications, use under an IDE, or uses outside FDA‑regulated homologous intent are treated as not medically necessary regardless of whether a product appears elsewhere in the policy. The policy therefore excludes such uses from coverage.
The policy limits repeated applications: more than one skin substitute application to the same wound on the same date is not medically necessary, and repeat or alternative full courses within 1 year after an unsuccessful prior course are not considered medically reasonable and necessary unless specific exception criteria are met. The policy also caps total applications per ulcer to a maximum over defined treatment episodes and sets a maximum episode duration (see product and limitations sections).
The policy emphasizes that skin substitutes are intended as adjuncts to — not replacements for — optimized standard care. Use of skin substitutes as a first‑line or replacement therapy without evidence of an adequate trial and optimization of standard treatments is not supported by the policy.
Skin substitutes should not be used as first‑line replacements for foundational etiology‑specific therapies. For VLUs this specifically means compression is foundational: substitutes are considered only after an adequate trial (commonly ≥4–6 weeks) of compression and standard wound care, and compression must be continued when adjunctive products are used.
Regulatory listing sections include product and FDA identifier references but do not contain explicit 'not medically necessary' determinations; coverage decisions are defined elsewhere in the policy by clinical criteria and exclusions.
Chunked regulatory listings (e.g., product names with PMA/510(k) identifiers and dates) are informational; these chunks do not declare products or indications as 'not medically necessary' and must be interpreted in the context of the policy's clinical criteria.
The regulatory identifier listings found in other chunks likewise do not make explicit 'not medically necessary' statements; they provide FDA mapping that may assist prior authorization or claims validation but do not override the clinical criteria in the coverage sections.
Additional regulatory listings (product names and K/P numbers) are informational only and do not include standalone coverage or exclusion language; medical necessity is determined by the clinical criteria sections of the policy.
Regulatory product lists that repeat FDA identifiers and product names are present for reference. These chunks do not provide coverage rules or state exclusions; coverage determinations rely on satisfaction of the policy's clinical criteria.
Examples of procedures or products that do not meet medical necessity criteria are provided in the exclusions section; the policy reiterates that items failing to meet the defined clinical criteria — including investigational or unproven treatments — are not eligible for coverage.
The exclusions section lists specific example product codes noted in noncoverage statements (for example, connective tissue nonhuman/synthetic code C1763 is cited under not medically necessary examples) to illustrate the policy's approach to excluded uses.
HCPCS C‑codes for collagen, nerve, and scaffold products (C9352–C9364 as listed) are designated Not separately payable in this policy — these items are considered integral to other services or lack evidence to support separate reimbursement.
As a general rule, treatments determined to be experimental, investigational, or unproven are excluded from coverage unless an approved exception is granted following individual case review and prior plan approval by a Priority Health medical director or clinical pharmacist.
Coding, HCPCS/CPT/ICD-10 and Regulatory Identifiers
| Q4116 | AlloDerm® / AlloDerm Regenerative Tissue Matrix (RTM) — Human Acellular Dermal Matrix |
| Q4100 | Cortiva® / AlloMax® / NeoForm® — Human Acellular Dermal Matrix (or listed equivalence) / may map to C9399 |
| Q4122 | DermACELL® — Human Acellular Dermal Matrix |
| Q4128 | FlexHD® — Human Acellular Dermal Matrix |
| Q4130 | Strattice™ — Xenograft Acellular Dermal Matrix |
| C9358 | SurgiMend® — Xenograft Acellular Dermal Matrix |
| C9360 | SurgiMend® — Xenograft Acellular Dermal Matrix (alternate code) |
| A2043 | Non-living biosynthetic dressing (example BIOBRANE Dressing) |
| A2044 | Partial-Thickness Burns / General Wound Matrix Coverage (used as grouping in document) |
| C9363 | Integra® Meshed Bilayer Wound Matrix / Bilayer Matrix Wound Dressing |
| Q4104 | Integra® Bilayer Matrix Wound Dressing (BMWD) / Bilayer Wound Matrix |
| Q4182 | TransCyte™ — Human fibroblast-derived temporary skin substitute |
| Q4105 | Integra® Dermal Regeneration Template (IDRT) |
| C9399 | Coding used for various cultured epidermal/cellular skin substitutes (e.g., Epicel®, OrCel™) and other products as listed |
| C8002 | Autologous skin cell suspension (ReCell®) — product-related code mapping |
| 15011 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| 15012 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| 15013 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| 15014 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| 15015 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| 15016 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| 15017 | Autologous skin cell suspension CPT/related codes (grouped 15011-15018 in document) |
| Q4128 | AlloPatch Pliable, Diabetic Foot Ulcers (DFUs) |
| Q4101 | Apligraf® (and other products listed under Q4101) |
| Q4102 | Oasis® Wound Matrix / Oasis® Ultra Tri-Layer Matrix |
| Q4124 | Tri-Layer Matrix |
| Q4105 | Omnigraft Dermal Regeneration Matrix |
| Q4431 | Dermagraft® |
| Q4121 | Theraskin® |
| Q4132 | Grafix® |
| Q4151 | AmnioBand® |
| Q4186 | EpiFix® |
| 270.5 | Porcine Skin and Gradient Pressure Dressings (NCD reference) |
| L36690 | LCD - Wound Application of Cellular and/or Tissue Based Products (CTPs), Lower Extremities (reference) |
| L36377 | LCD - Application of Skin Substitute Grafts for Treatment of DFU and VLU (reference) |
| L35041 | LCD - Application of Bioengineered Skin Substitutes to Lower Extremity Chronic Non-Healing Wounds (reference) |
| NCD 270.5 | Porcine Skin and Gradient Pressure Dressings (reference to CMS NCD numbering in policy) |
| LCD L36690 | Wound Application of Cellular and/or Tissue Based Products (CTPs), Lower Extremity |
| LCD L36377 | Application of Skin Substitute Grafts for Treatment of DFU and VLU of Lower Extremities (First Coast Service Options, Inc.) |
| LCD L35041 | Application of Bioengineered Skin Substitutes to Lower Extremity Chronic Non-Healing Wounds (Novitas Solutions, Inc.) |
| K130817 | Strattice (510(k) number) listed under breast reconstruction |
| K071807 | SurgiMend (510(k) number) |
| K140533 | Galaflex (510(k) number) |
| K161092 | GalaShape 3D (510(k) number) |
| K162922 | Galaform 3D (510(k) number) |
| K896110 | BIOBRANEII (510(k)/PMA details) |
| K242146 | BIOBRANE Temporary Wound Dressing and Glove |
| P010016 | OrCel™ (PMA/HDE reference) |
| P900033 | Integra® Dermal Regeneration (PMA) |
| K021792 | Integra Bilayer Matrix Wound Dressing (510(k)) |
| P950032A | FDA product identifier referenced for Epifix / Apligraf/Graftskin in ulcers/diabetic foot ulcers listings |
| K061711 | FDA/510(k) or device identifier referenced for products in the list (e.g., Epifix referenced) |
| P000036A | FDA product identifier referenced for Dermagraft or related products |
| P900033 | FDA product identifier referenced for Integra Omnigraft Dermal / Regeneration Matrix |
| s042 | Suffix or combined identifier shown as P900033/s042 in document |
| BP170122 | Reference code appearing alongside diabetic foot ulcer entries |
| K153690 | K-number referenced in the regulatory listings |
| K102002 | K-number referenced in the regulatory listings |
| P950032A | Apligraf/Graftskin (listed) |
| K061711 | Oasis Wound Matrix (listed) |
| P000036A | Dermagraft (listed) |
| P900033 | Integra Dermal Regeneration/Omnigraft (listed) |
| P900033/s042 | Integra Dermal Regeneration Matrix (listed) |
| K153690 | Primatrix (listed) |
| K102002 | Talymed (listed) |
| K112409 | Matristem Wound Matrix (listed) |
| K172399 | Additional 510(k) referenced (listed) |
| K132343 | Additional 510(k) referenced (listed) |
| P950032A | Apligraf/Graftskin |
| K061711 | Oasis® Wound Matrix and Oasis Ultra Tri-Layer Matrix |
| P000036A | Dermagraft |
| P900033/s042 | Integra Omnigraft Dermal Regeneration Matrix |
| P900033 | Integra Dermal Regeneration Matrix |
| K153690 | Primatrix |
| K102002 | Talymed |
| K112409 | Matristem Wound Matrix |
| K172399 | Matristem MicroMatrix |
| K132343 | Kerecis™ Omega3 Wound (formerly MeriGen) |
| P900033/s042 | Integra Omnigraft Dermal Regeneration Matrix |
| P900033 | Integra Dermal Regeneration Matrix |
| P000036A | Dermagraft |
| P950032A | Apligraf/Graftskin |
| K061711 | Oasis Wound Matrix and Oasis Ultra Tri-Layer Matrix |
| K153690 | Primatrix |
| K102002 | Talymed |
| K112409 | Matristem Wound Matrix |
| K172399 | Matristem MicroMatrix |
| K132343 | Kerecis™ Omega3 Wound (formerly known as MeriGen) |
| K112409 | Matristem Wound Matrix |
| K172399 | Matristem MicroMatrix |
| K132343 | Kerecis Omega3 Wound (formerly MeriGen) |
| K190528 | Kerecis Limited MariGen Wound Extra / Marigen Wound Extra |
| K213231 | Kerecis Silicone (Kerecis Limited) |
| K241080 | Kerecis Parvus |
| K061711 | Oasis Wound Matrix and Oasis Ultra Tri-Layer Matrix |
| P000036A | Dermagraft |
| P900033/s042 | Integra Omnigraft Dermal Regeneration Matrix |
| P900033 | Integra Dermal Regeneration Matrix |
| K132343 | Kerecis Limited MariGen Wound Extra |
| K190528 | Kerecis Silicone (Kerecis Limited) |
| K213231 | Kerecis Parvus |
| K241080 | Marigen Wound Extra |
| K161067 | Mirragen™ Advanced Wound Matrix (listed) |
| P000036A | Dermagraft (Dermagraft entries) |
| P900033 | Integra Omnigraft Dermal Regeneration Matrix / Integra Dermal Regeneration Matrix |
| P900033/s042 | Integra Omnigraft Dermal Regeneration Matrix (supplement) |
| P950032A | Apligraf/Graftskin |
| P950032/S016 | Apligraf/Graftskin (supplement) |
| Epifix | Epifix (HCT/P) — listed as HCT/P product |
| C50.011 - C50.929 | Malignant neoplasm of female breast |
| C79.81 | Secondary malignant neoplasm of breast |
| D05.00 - D05.92 | Carcinoma in situ of breast |
| D48.60 - D48.62 | Neoplasm of uncertain behavior of breast |
| D49.3 | Neoplasm of unspecified behavior of breast |
| T85.44xA - T85.44xS | Capsular contracture of breast implant |
| N65.0 | Deformity of reconstructed breast |
| N65.1 | Disproportion of reconstructed breast |
| Z85.3 | Personal history of malignant neoplasm of breast |
| Z42.8 | Encounter for other plastic and reconstructive surgery following medical procedure or healed injury |
| E08.40 - E08.610 | Diabetes mellitus due to underlying condition with diabetic neuropathy |
| E09.40 - E09.610 | Drug or chemical induced diabetes mellitus with neurological complications |
| E10.40 - E10.69 | Type 1 diabetes mellitus with neurological complications |
| E11.40 - E11.69 | Type 2 diabetes mellitus with neurological complications |
| E13.40 - E13.69 | Other specified diabetes mellitus with neurological complications |
| 15011 | Harvest of skin for skin cell suspension autograft; first 25 sq cm or less |
| 15012 | Harvest of skin for skin cell suspension autograft; each additional 25 sq cm or part thereof |
| 15013 | Preparation of skin cell suspension autograft; first 25 sq cm or less of harvested skin |
| 15014 | Preparation of skin cell suspension autograft; each additional 25 sq cm of harvested skin |
| 15015 | Application of skin cell suspension autograft to wound and donor sites; first 480 sq cm or less |
| 15016 | Application of skin cell suspension autograft; each additional 480 sq cm or part thereof |
| 15017 | Application of skin cell suspension autograft to specialized sites; first 480 sq cm or less |
| 15018 | Application of skin cell suspension autograft to specialized sites; each additional 480 sq cm or part thereof |
| C8002 | Processing and device components (automated skin cell suspension processing) - descriptor present |
| 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 |
| A2043 | Biobrane, per square centimeter |
| A2044 | Biobrane glove, each |
| C9358 | Dermal substitute, native, nondenatured collagen, fetal bovine origin (SurgiMend Collagen Matrix), per 0.5 sq cm |
| C9360 | Dermal substitute, native, nondenatured collagen, neonatal bovine origin (SurgiMend Collagen Matrix), per 0.5 sq cm |
| C9363 | Skin substitute (Integra Meshed Bilayer Wound Matrix), per sq cm |
| Q4100 | Cortiva® (formerly AlloMax®, NeoForm®); DermaMatrix®; Skin substitute NOS (add-on guidance) |
| Q4101 | Apligraf, per sq cm |
| Q4102 | Oasis wound matrix, per sq cm |
| Q4104 | Integra bilayer matrix wound dressing (BMWD), per sq cm (add-on) |
| Q4105 | Integra dermal regeneration template (DRT) or Integra Omnigraft dermal regeneration matrix, per sq cm |
| A2043 | Biobrane, per square centimeter |
| A2044 | Biobrane glove, each |
| C9358 | Dermal substitute, native, nondenatured collagen, fetal bovine origin (SurgiMend Collagen Matrix), per 0.5 sq cm |
| C9360 | Dermal substitute, native, nondenatured collagen, neonatal bovine origin (SurgiMend Collagen Matrix), per 0.5 sq cm |
| C9363 | Skin substitute (Integra Meshed Bilayer Wound Matrix), per sq cm |
| Q4100 | Cortiva® (formerly AlloMax®, NeoForm®); DermaMatrix® |
| Q4101 | Apligraf, per sq cm |
| Q4102 | Oasis wound matrix, per sq cm |
| Q4104 | Integra bilayer matrix wound dressing (BMWD), per sq cm |
| Q4105 | Integra dermal regeneration template (DRT), per sq cm |
| A2001 | InnovaMatrix AC (per sq cm) - Not separately payable (add-on; reported with primary procedure) |
| A2002 | Mirragen Advanced Wound Matrix (per sq cm) - Not separately payable (add-on) |
| A2004 | XcelliStem (1 mg) - Not separately payable |
| A2013 | InnovaMatrix FS (per sq cm) - Not separately payable (add-on) |
| A2014 | Omeza Collagen Matrix (per 100 mg) - Not separately payable |
| A2016 | Permeaderm-B (per sq cm) - Not separately payable (add-on) |
| A2017 | Permeaderm Glove (each) - Not separately payable (add-on) |
| A2018 | Permeaderm-C (per sq cm) - Not separately payable (add-on) |
| A2019 | Kerecis Omega3 MariGen Shield (per sq cm) - Not separately payable (add-on) |
| A2020 | AC5 Advanced Wound System (AC5) NeoMatriX® (per sq cm) - Not separately payable (add-on) |
| Q4168 | AmnioBand® Add-on; listed in addition to primary procedure |
| Q4169 | Artacent® Wound Add-on; listed in addition to primary procedure |
| Q4170 | Cygnus® Add-on; listed in addition to primary procedure |
| Q4171 | Interfyl® Add-on; listed in addition to primary procedure |
| Q4173 | PalinGen® Add-on; listed in addition to primary procedure |
| Q4174 | PalinGen® ProMatrX® Add-on; listed in addition to primary procedure |
| Q4175 | Miroderm® Add-on; listed in addition to primary procedure |
| Q4177 | FlowerAmnioFlo® Add-on; listed in addition to primary |
| Q4178 | FlowerAmnioPatch® Add-on; listed in addition to primary |
| Q4179 | FlowerDerm® Add-on; listed in addition to primary |
| Q4309 | Procenta (per 100 mg) injectable / particulate form |
| Q4310 | Acesso (per sq cm) Add-on; listed in addition to primary procedure |
| Q4311 | Acesso AC (per sq cm) Add-on |
| Q4312 | DermaBind FM (per sq cm) Add-on |
| Q4313 | Reeva FT (per sq cm) Add-on |
| Q4319 | SanoGraft (per sq cm) Add-on |
| Q4320 | PelloGraft (per sq cm) Add-on |
| Q4321 | RenoGraft (per sq cm) Add-on |
| Q4322 | CaregraFT (per sq cm) Add-on |
| Q4323 | alloPLY (per sq cm) Add-on |
| C9352 | Microporous collagen implantable tube (NeuraGen® Nerve Guide), Per centimeter length — Not separately payable |
| C9353 | Microporous collagen implantable slit tube (NeuraWrap® Nerve Protector), Per centimeter length — Not separately payable |
| C9354 | Acellular pericardial tissue matrix of nonhuman origin (Veritas®), Per square centimeter — Not separately payable |
| C9355 | Collagen nerve cuff (NeuroMatrix®), Per 0.5 centimeter length — Not separately payable |
| C9356 | Tendon porous matrix of cross-linked collagen and glycosaminoglycan (TenoGlide® Tendon Protector Sheet), Per square centimeter — Not separately payable |
| C9359 | Porous purified collagen matrix bone void filler (Integra® Mozaik Osteoconductive Scaffold Putty), Per 0.5 cc — Not separately payable |
| C9361 | Collagen matrix nerve wrap (NeuroMend® Collagen Nerve Wrap), Per 0.5-centimeter length — Not separately payable |
| C9362 | Porous purified collagen matrix bone void filler (Integra® Mozaik Osteoconductive Scaffold Strip), Per 0.5 cc — Not separately payable |
| C9364 | Porcine implant (Permacol®), per sq cm — Not separately payable |
| P900033 | INTEGRA® Dermal Regeneration Template - PMA identifier (FDA PMA P900033) |
| P010016A | ORCEL® bilayered cellular matrix - PMA identifier (FDA PMA P010016A) |
| P960007 | TransCyte™ temporary wound covering - PMA identifier (FDA PMA P960007) |
| K061711 | Oasis® Wound Matrix - 510(k) summary (K061711) |
| K083898 | SurgiMend® Collagen Matrix - 510(k) (referenced earlier in document portion) |
Prior Authorization, Documentation, Billing and Denial Risk
Prior authorization required for listed product codes
Obtain prior authorization per payer process for the specific HCPCS/CPT/product codes listed in the policy before billing; inclusion of a product in coding tables does not itself establish medical necessity.
Prior authorization and code-based utilization limits
When product-specific HCPCS codes are used, obtain prior authorization consistent with the utilization limits in each product section (initial application limits and maximum total applications within a 12‑week episode).
- Example limits: AlloPatch (Q4128) — initial ≤5 applications; up to 8 applications per ulcer within 12 weeks. Dermagraft (Q4431) — initial ≤5; up to 8 in 12 weeks. Many products: initial 1 and up to 4–5 applications in 12 weeks depending on product.
- Applications beyond 12 weeks per ulcer are not medically necessary.
Prior authorization may be required per CMS/LCD
Confirm whether CMS NCDs/LCDs or local coverage articles apply and obtain prior authorization when required by those determinations or by the member's plan.
- MAC/LCD/NCD guidance takes precedence; check the Medicare Coverage Database and the member's plan documents.
Prior authorization for adjunctive skin substitute use
Obtain prior authorization for adjunctive skin substitute use when the policy requires the product to be used only after failure of optimized standard care and when product-specific indications include adjunctive use.
- Document prior conservative management (debridement, dressings, infection control, offloading for DFU or compression for VLU) when submitting the authorization request.
Include FDA product/clearance identifiers in PA submissions
Reference the FDA product/clearance identifiers and device names listed in the regulatory sections when submitting prior authorization or coverage review documentation for a specific product.
- Examples of FDA identifiers in the policy: P950032A, K061711, P000036A, P900033/s042, BP170122.
FDA device identifiers for PA verification
Use the FDA PMA/510(k)/HCT/P numbers provided in the policy to help verify product regulatory status during prior authorization review.
- Cite identifiers such as P950032A (Apligraf), K061711 (Oasis), P000036A (Dermagraft), and P900033 variants when relevant.
Regulatory listings do not by themselves require PA
This regulatory listing section enumerates FDA identifiers for products and does not impose additional prior authorization requirements by itself.
- Regulatory listings are informational; prior authorization requirements are described elsewhere in the policy or by the payer.
No PA rule stated in regulatory listing
The regulatory identifier tables provide FDA clearance/approval numbers and product names but do not specify prior authorization rules; use them for verification only.
- Providers should not assume authorization requirements from these listings alone.
FDA clearance references (informational)
FDA clearance references and identifiers are listed for provider reference; they support verification during utilization review but do not establish prior authorization criteria.
- Documented examples include K112409, K172399, and K132343 among others.
Regulatory listing — PA not specified here
Regulatory product identifiers are listed for reference; the policy's regulatory listings do not themselves mandate prior authorization.
- Use these identifiers when validating product clearance during PA or claims review.
Prior authorization and correct billing for application/product
Obtain any required prior authorization before billing skin substitute application and related product codes; ensure the application code and product code are billed together on the same claim for the same date of service.
- Application codes (e.g., 15271–15278, G0681–G0684) must be billed on same claim with product HCPCS/CPT codes.
- Follow payer prior authorization process when required.
Report exact product HCPCS/CPT and follow add-on instructions
Bill the exact HCPCS/CPT product code(s) that correspond to the product used and follow add-on/list-separately instructions where noted in the coding section.
- Many product HCPCS (Q-codes) are designated add-on and must be listed separately in addition to the primary procedure.
Use mapped Q-code for add-on/excluded products
When a product is designated as an add-on or excluded item in the policy, bill the mapped Q-code and list it in addition to the primary procedure; do not bill it as a standalone primary procedure.
PA may be required — submit medical necessity documentation
Prior authorization may be required for certain products or procedures; when required, submit documentation demonstrating medical necessity and follow the plan's prior authorization process.
- Individual case review with prior plan approval is required for investigational or unproven treatments.
When PA is required, obtain plan approval with supporting documentation
If prior authorization is required, providers must submit requests showing medical necessity and obtain plan approval; individual case review may allow coverage for investigational treatments with prior approval.
- Decisions for investigational treatments are made by a Priority Health medical director or clinical pharmacist.
Document ≥4 weeks failed standard care (≥50% area reduction threshold)
Document and demonstrate failure of an adequate trial of standard wound care (e.g., wound failed to show ≥50% area reduction after ≥4 weeks of documented standard care) before requesting advanced skin substitute therapy.
- Standard care components include debridement when indicated, appropriate dressings, infection assessment/management, and etiology-specific measures (offloading for DFU; compression for VLU).
Adjunctive use only — document standard care and rationale
Use skin substitutes only as adjuncts after an adequate trial of standard wound care (debridement, dressings, infection control, and etiology-specific therapy) and document the rationale for adjunctive product selection.
- Adjunctive use must not replace foundational therapy (e.g., offloading or sustained compression).
Stepwise escalation — optimize foundational care before advanced products
Follow a stepwise escalation strategy: optimize etiology-specific standard care (e.g., compression for VLUs; offloading for DFUs) and escalate to product-specific adjunctive therapies only when wounds fail to progress.
- Consider RCT-proven advanced agents for chronic DFUs that fail to heal with optimal standard care.
Maintain optimized etiology-specific standard care before application
Optimize and continue etiology-specific standard care (compression for VLUs; offloading and diabetes management for DFUs) before and during adjunctive skin substitute therapy.
- For DFU, ensure offloading is maintained and HbA1c assessment and diabetes optimization are documented.
Regulatory listing — no step therapy rules here
This regulatory listing chunk is informational and does not impose step therapy or authorization actions; consult the clinical criteria sections for required prerequisites.
- Regulatory identifiers here are for provider reference only.
Regulatory listings — no PA or step therapy specified
Regulatory identifier listings in this section are informational; they do not specify provider actions or authorization steps.
- Use identifiers for verification, but follow clinical criteria elsewhere in the policy.
Check plan-level requirements and member benefits
Plan- or group-specific documents may impose additional utilization rules; verify member-specific benefits and any state-mandated provisions before requesting authorization or billing.
- For self-funded (ASO) and individual plans consult the plan document; Medicare coverage is determined by CMS when an NCD/LCD applies.
Document wound assessment, infection control, and treatment plan
Include the following clinical details in prior authorization and chart documentation: wound depth, total body surface area (when relevant), anatomic location, functional risk areas, wound bed status and infection control, and a treatment plan explaining why standard therapy alone is insufficient.
- For burns include TBSA, burn depth, and donor-site considerations; for ulcers include serial wound measurements and healing trajectory.
DFU-specific documentation: diabetes status, HbA1c, offloading
For DFU prior authorizations and charting, document diabetes type, recent HbA1c (within 90 days), evidence that diabetes management is being optimized, and that effective offloading is in place.
- Policy requires HbA1c <12% within 90 days unless documentation justifies proceeding despite higher values.
Document wound depth, no exposed deep structures, and ≥4 weeks SOC adherence
Before application, document wound depth (partial/full-thickness), absence of exposed bone/tendon/muscle/joint capsule, adherence to ≥4 weeks of standard wound care, and objective perfusion assessment as applicable (palpable pulses, ABI, toe pressure/TBI).
- Record serial wound measurements and percent area change to support failure of standard care (e.g., <50% reduction after ≥4 weeks).
Document optimized standard care and vascular assessment
Document that standard wound care was optimized (debridement when indicated, infection assessment/management, moisture balance) and include objective vascular assessment (ABI, toe pressure, or TBI) and wound healing trajectory in the record.
- Include notes on offloading for DFU or sustained compression for VLU and serial percent area changes after 4 weeks.
Document diagnosis, duration, response to SOC, and product rationale
Confirm and document the diagnosis (e.g., VLU with venous disease evaluation and exclusion/assessment of arterial disease), duration and response to an adequate trial of standard care, wound measurements/serial progress, and rationale for the chosen adjunctive product when submitting prior authorization.
- For VLU include documentation of sustained compression therapy and venous evaluation.
Reference FDA identifiers for coverage and claims validation
Consult the regulatory identifier tables for FDA product identifiers when validating product regulatory status for coverage or claims submission; include matching product identifiers when available.
- Examples: P950032A (Apligraf), K061711 (Oasis), P000036A (Dermagraft).
Document product name and FDA 510(k)/PMA identifier
Document the exact product name and corresponding FDA 510(k) or PMA identifier (when applicable) in the prior authorization and claims submission to support verification.
- Policy examples: Oasis K061711; Dermagraft P000036A; Apligraf P950032A.
Include supporting ICD-10 diagnosis codes
Use the listed ICD-10 diagnosis codes to support medical necessity on authorization requests and claims when applicable to the clinical indication.
- Examples include L97.x for non-pressure chronic ulcers, I83.x for venous ulcers, and diabetes codes E10–E13 with complications.
Provide explanatory notes for unlisted/NOS skin substitute codes
When billing with an unlisted or 'NOS' skin substitute code (e.g., Q4100 or other unlisted device codes), include an explanatory note describing the product, reason for use, and relation to the primary procedure.
- Unlisted device lines should be accompanied by clinical rationale and product details to support medical necessity and coding.
Bill using policy mapping; adhere to add-on Q-code designations
Follow the policy's billing designations and Q-code mapping when submitting claims; many named products are designated 'Add-on; listed in addition to primary procedure' and must be billed accordingly.
- Failure to bill add-on items as specified may trigger claim review or denial.
Submit medical necessity evidence with PA; investigational treatments need prior approval
When prior authorization is required, submit documentation that demonstrates medical necessity; individual case review may allow coverage for investigational treatments only with prior plan approval.
- Exceptions for investigational treatments require review by a Priority Health medical director or clinical pharmacist and prior plan approval.
Denial risk: missing wound documentation
Failure to document wound characteristics, adherence to standard care, and a treatment plan prior to application may result in denial of coverage.
- Documentation prerequisite explicitly required by the policy (wound characteristics and treatment plan present prior to application).
Denial risk: inadequate trial of standard care
If an adequate trial of standard wound care (commonly ≥4 weeks; ≥4–6 weeks for VLUs) is not documented, the request may be denied for failure to meet policy prerequisites.
- Policy cites failure to demonstrate ≥50% area reduction after ≥4 weeks as a common clinical decision point for escalation.
Denial triggers: applications >12 weeks or >10 total in 12 weeks
Treatments beyond 12 weeks per ulcer or more than ten total applications per ulcer within a 12‑week episode are considered not medically necessary and may be denied.
- Multiple different substitutes concurrently or sequentially for the same ulcer without documented rationale is also not medically necessary.
CMS/LCD precedence may affect authorization and coverage
Coverage may be governed by applicable federal/state mandates and CMS NCD/LCD determinations; failure to follow those mandates or local coverage rules can trigger denials.
- Refer to the Medicare Coverage Database for current NCD/LCD/LCA guidance.
Claim denial risk: application and product codes must be billed together
Failure to bill the appropriate skin substitute application code together with the product code on the same claim for the same date of service may result in claim denial.
- Ensure application CPT/HCPCS (e.g., 15271–15278, G0681–G0684) and product HCPCS/Q-code are on the same claim and date of service.
Denial risk: non‑medically necessary items per policy
Claims for products that do not meet the policy's medical necessity criteria (including excluded, investigational, or unproven items) are not eligible for coverage and may be denied.
- Examples include prophylactic use on closed ulcers, infected/ischemic wounds not adequately treated, and routine cosmetic uses outside criteria.
Denial risk: exclusions and add-on billing must be followed
Products listed as add-on or not separately payable must be billed as add-on items (in addition to the primary procedure); incorrect submission or billing as standalone may result in denial.
- Large lists of Q-codes are designated as add-on/not separately payable; review the coding section and bill accordingly.
Denial risk for excluded Q/HCPCS codes billed incorrectly
Claim lines using Q-codes or HCPCS codes designated as add-on or not separately payable may be denied if billed incorrectly or outside the policy rules.
- Verify mapping and add-on designation before submitting claims to avoid denials.
Denial risk: investigational/experimental treatments require prior approval
Coverage determinations for investigational, experimental, or unproven treatments require individual case review and prior plan approval; absent approved exception, such treatments are generally excluded from coverage.
- Allowed exceptions are limited (e.g., terminal illness or chronic, deteriorating severe disease) and require review by a medical director or clinical pharmacist.
Background and Rationale
Skin substitutes and acellular dermal matrices are used as adjuncts to provide temporary or definitive wound coverage, to supply a scaffold that supports revascularization and granulation, and to reduce fluid loss or contamination risk. Because composition and intended use vary, clinical outcomes and risks are interpreted on a product‑ and indication‑specific basis, and the strongest evidence may be limited to selected products and settings.
Definitions and Terms
OpenPayer is powered by Trek Health's payer performance platform. Trek continuously ingests, validates, and normalizes Transparency in Coverage data alongside payer policies and other commercial payer data to create a structured payer intelligence foundation. OpenPayer uses this foundation to deliver personalized search results, dynamically generated policy pages, and tailored policy monitoring based on each user's payers, specialties, billing codes, and areas of interest. The same intelligence powers broader payer performance workflows, including reimbursement benchmarking, contract evaluation, payer negotiations, and financial decision-making.