CMS has clarified that providers may no longer bill Medicare for wastage associated with the use of non-BLA skin substitute products as of January 1. The JZ and JW Modifiers should no longer be used for skin substitute application for Medicare beneficiaries. Members are encouraged to choose a product size that is most appropriate for the wound size and minimize waste. If a portion of a non-BLA skin substitute is discarded, the provider may only bill Medicare for the units that are administered. The only exception to this is skin substitute products marketed under a BLA, as set forth in section 351 of the Public Health Services (PHS) Act.
Members with questions or concerns are encouraged to contact the APMA Advocacy Department.