Recent reforms proposed by the Centers for Medicare & Medicaid Services (CMS) were designed to tackle waste and soaring costs in advanced wound care—specifically around skin substitutes, also known as cellular, acellular, and matrix-like products (CAMPs). While the intent is to curb fraud and level the playing field, the reality is much more complex. Our latest collective work led by Bill Tettelbach, just published in the Journal of Wound Care, shows the current blueprint risks reducing access to life-saving technologies, destabilizing care for our most vulnerable, and slowing innovation in wound healing.
What’s at Stake?
CAMPs are transformational for patients with hard-to-heal wounds—prevalent among older adults, the medically underserved, and people with chronic illnesses. But new payment reforms introduce substantial risks:
- Concentrated Use: A Stark Imbalance
- In 2023, the top 10 non-facility providers accounted for 26% of total Medicare CAMP spending—compared to just 5% in facility settings.
- Expanding to the top 100 providers, they were responsible for 63.9% of all Medicare non-facility CAMP spending, representing only 6.7% of patients and 14.4% of service dates.
- Fewer than 3% of non-facility providers performed 63.9% of all CMS spending on CAMPs, leaving the other 97% responsible for the remaining 36.1%.
- Among these concentrated providers, average per-patient spend was $346,906—that’s 24.5 times higher than the $14,123 average among other providers.
- The average CAMP size applied by these providers was 56.7 cm², versus 11.9 cm² for the rest.
- Waste, Fraud, and Abuse: While nearly $1 billion in federal indictments shows waste and fraud are real, broad-stroke payment cuts risk penalizing ethical providers and decreasing access for the majority of patients.
- Financial Sustainability: Proposed flat-fee reimbursement often doesn’t cover the cost of CAMPs, especially for community practices and mobile wound care—threatening care availability outside of large hospitals.
- Access and Health Equity: Smaller/rural clinics face even greater challenges stocking effective therapies—widening the care gap for underserved populations.
- Clinical Effectiveness: A flat-rate, “one-size-fits-all” system ignores complex clinical needs, especially for severe wounds. Evidence shows advanced CAMPs can reduce wound recurrence by up to 91% and may decrease amputation and mortality risk.
- Unintended Consequences: Restricting the best therapies early may raise long-term costs, through more ER visits, hospitalizations, amputations, and avoidable deaths.
Our Policy Proposals—A Roadmap Forward
Rather than blunt methods, we call for nuance and targeted solutions:
- Smart Oversight: Move from slow audits to AI-driven, real-time analysis, identifying outlier patterns early and protecting both patient care and taxpayer dollars.
- Target Outliers: Focus corrective actions on the small group of very high-use providers rather than enacting cuts impacting all.
- Protect Access: Design reimbursement based on clinical need and real-world evidence, not just cost-cutting or acquisition price.
- Fair Flat-Fees: If using flat rates, set them based on true value—outcomes, manufacturing cost, and the full range of patient populations.
- Support Equity: Ensure rural and safety-net providers are sustainable, not just large urban centers.
- Evidence-Based Coverage: Require consistent national coverage determinations rooted in robust clinical data.
- Continuous Policy Improvement: Enable dynamic feedback between providers and CMS, monitoring not just cost but patient outcomes and system efficacy.
- Promote Innovation: Link payments to the complexity and value of new CAMP technologies, supporting ongoing medical advances.
Why This Matters
The way we fund wound care shapes outcomes for millions. As the debate around CMS reforms unfolds, it is crucial for policymakers to balance fiscal responsibility with equitable access and ongoing innovation.
Read the full study:
Tettelbach Armstrong et al., Journal of Wound Care, 2025
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