Hi Chris, 

According to the future effective LCDs and Articles: 

"The skin substitute graft/CTP must be used in an efficient manner utilizing the most appropriate size product available at the time of treatment. Excessive wastage (discarded amount) should be avoided by utilization of size appropriate packaging of the product consistent with wound size. The graft must be applied in a single layer without overlay of product or adjacent skin in compliance with the correct label application techniques for the skin substitute graft/CTP." ​(LCDs currently scheduled to take effect on April 13, 2025 - if nothing happens before that)

"Any amount of wasted skin substitute graft/CTP must be clearly documented in the procedure note with ALL of the following information (at a minimum): Date, time and location of ulcer(s) treated; Name of skin substitute graft/CTP and package size: Approximate amount of product unit used; Approximate amount of product unit discarded; Reason for the wastage (including the reason for using a package size larger than was necessary for the size of the ulcer, if applicable); Manufacturer’s serial/lot/batch or other unit identification number of graft/CTP material. When the manufacturer does not supply unit identification, the record must document such. The amount billed as wastage cannot exceed the price of the package." ​(Current Article and Articles currently scheduled to take effect on April 13, 2025 - if nothing happens before that)

So according to the excerpts above, it seems like if the provider is using 100% of the CTP appropriately - such as cutting it into smaller pieces to line the wound walls without overlaying the product - there should be no need to report waste. As long as the entire graft is applied in a single layer to the wound bed, it would be considered fully utilized.

 Additionally, the articles outline specific documentation requirements for reporting wasted CTP, including details such as the amount discarded, the reason for wastage, and manufacturer information. As such, it seems like if no material is discarded and the full product is used appropriately, there should be no wastage to report.

• CPT articles and LCDs scheduled to take effect on 4/13/25 are standardized across all Medicare Administrative Contractors (MACs), to ensure uniform application nationwide.
• One of the future effective articles : https://www.cms.gov/medicare-coverage-database/view/article.aspx?articleId=59626&ver=6
• One of the future effective LCD : https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdId=39760&ver=7
• Cellular and/or Tissue Based Products (see topic, documentation checklist) https://woundreference.com/app/topic?id=cellular-andor-tissue-products

Hope this helps