Defining appropriate CAMPs administration: a response to the Medicare wastage guidance

Expert panel recommendationsDefining appropriate CAMPs administration: a response to the Medicare wastage guidance T he recent change in the Centre for Medicare and Medicaid Services (CMS) physician fee schedule (PFS) to reclassify cellular, acellular and matrix-like products (CAMPs) as an incident-to-supply has created confusion about the appropriate use, administration and documentation of this technology.There is particular uncertainty about how to interpret the terms 'wastage', 'administered' and 'discarded' in relation to CAMPs usage and the implications for reimbursement.CMS regards incident-to-supply items as an integral, but incidental part, of a clinician's service.The consternation relates to the following answers by CMS in its frequently asked questions section for the JW modifier and JZ modifier policy: 1 • 'As long as the discarded amount is accurately documented, CMS does not dictate how it is calculated.' • 'Under Medicare Part B, the JW and JZ modifiers are only used when billing for drugs and biologicals, which are separately payable.The JW and JZ modifiers are not appropriate for billing incident-to supplies, even if such incident-to supplies are payable separately.' • 'In addition, discarded amounts of incident-to supplies are not payable by Medicare.'• 'Non-BLA skin substitutes are no longer payable underMedicare Part B as a drug or biological as of January 1, 2026, and only the administered portion is payable.' • 'If a provider or supplier administers a portion of a non-BLA skin substitute from the package or container and a portion is discarded, the provider or supplier may only bill for the units administered.It is not appropriate to bill Medicare for such discarded units under any circumstance.'However, the clinical reality is that hard-to-heal wounds that have not responded to standard of care have a diverse three-dimensional topography.The traditional two-dimensional length × width measurement fails to capture the true volume and topography of most wounds.In practice, a larger sized CAMP product might be needed than the initial length × width measurement indicated.Hence, the uncertainty about how to define 'wastage' and anxiety about the risk of clawbacks.Clinicians need to regain confidence to continue using CAMPs to promote healing in recalcitrant wounds.Doing so will require greater clarity on how to demonstrate medical necessity, ensure appropriate CAMP size selection, and avoid excessive product utilisation.