National Coverage Analysis (NCA) View Public Comments

Non-Autologous Blood Derived Products for Chronic Non-Healing Wounds

Public Comments

Commenter Comment Information
quinn, bruce Date: 02/17/2006

Because this area has somewhat dense and potentially confusing terminology, it would be helpful for readers to briefly state in the NCD some of the collateral information in the NCA discussion. People will think, well, platelet- rich plasma contains autologous growth factors, and so forth. To whit, why not clearly but briefly state a few phrases such as, "Carrier discretion governs coverage of platelete-rich plasma (PRP) for acute surgical wounds and the use of beclapermin within its FDA-


Thimsen, Kathleen Title: CEO
Organization: RARE Consulting Group, Inc
Date: 02/14/2006

I agree with the non-coverage policy as the products (as mentioned) are drug technology and I believe should be covered under the drug benefit. A second comment is that this type of technology/treatment should have some end point of use and check-points of positive outcomes.

Example: I saw a patient who had been using Regranex for 7 years on a leg wound. It was being prescribed for a wound that had no granulation tissue, the bone was exposed, the wound edges epibolized and the woma had