09/11/2025    Paul Kesselman, DPM

Flat Rate Payments for CAMP

As every medical professional seems to understand,
CMS has put their stamp on the need to radically
curtail spending on Cellular Tissue Products.
While this is laudable, a recent article in the
Journal of Wound Care, entitled Safeguarding
access, fiscal responsibility and innovation: a
comprehensive reimbursement framework for CAMPAs
to preserve the Medicare Trust Fund" with
headlined authors including our own David
Armstrong, DPM and Vicki Driver, DPM points out
that "An analysis of 2,023 Medicare claims data
demonstrated that 26% of total CAMPs spending came
from just the top 10 providers in non-facility
settings, compared to only 5% in facility
settings. When expanded to the top 100 providers,
the disparity becomes even more pronounced,
accounting for an astounding approximately 64% of
non-facility spending versus just 19% in the
facility setting.

To put this in perspective, fewer than 3% of non-
facility providers billing for CAMPs applications
are responsible for 63.9% of all CMS spending in
this category, while the remaining 97.3% of
providers account for just 36.1% of spending. This
extreme concentration of use underscores that the
primary cost drivers are a very small subset of
high-intensity providers, rather than the broader
wound care community." The full article can be
read at
https://www.magonlinelibrary.com/doi/full/10.12968
/jowc.2025.0396

This conclusion is something which should draw the
ire of every wound care provider.And it would seem
that CMS is simply throwing the baby out with the
bathwater.
It is a terrible injustice to punish all the
providers for the few bad actors. Certainly our
patients will suffer the indignity of limb loss
and at what costs? There is the WISeR and other
prior authorization programs that can cut out the
bad actors and accomplish the goals of preserving
patient access to a much needed service from the
vast majority of providers who provide this
service ethically.

Today's APWCA bulletin provides a link to this
article as well as the ability for you to share
your comments (until September 12) with CMS.
Please go to the APWCA website where your voice
can be heard. You need not be a member.
Signing a petition is as easy as going to:
https://www.whacares.org/advocacy or submitting
comments to CMS at
https://www.regulations.gov/commenton/CMS-2025-
0304-1544

Paul Kesselman, DPM, Oceanside, NY

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