Reports Suggest NGS May Have Removed Language on CTP Restriction in Skilled Nursing Facilities
Key Takeaways
1. Unverified but potentially meaningful policy signal
Industry stakeholders report that NGS may have removed prior language restricting CTP use in SNFs (POS 32), but no formal confirmation has been issued.
2. Potential impact on site-of-care and provider strategy
If confirmed, the change could influence how wound care providers—particularly mobile and post-acute groups—approach CTP utilization, documentation, and care delivery in SNF settings.
3. Occurs amid broader reimbursement and advocacy activity
The reported update comes during heightened scrutiny of CTP reimbursement and access, suggesting it may reflect ongoing regulatory pressure, advocacy efforts, or contractor-level recalibration.
Industry stakeholders, including the Wound and Hyperbaric Association, are reporting that National Government Services (NGS) has removed prior website language restricting the use of cellular and tissue-based products (CTPs)—commonly referred to as skin substitutes—in Place of Service (POS) 32, which includes skilled nursing facilities (SNFs) and long-term care settings.1 However, formal confirmation from NGS has not yet been identified.
The reported change, which has circulated among wound care clinicians and executives on LinkedIn and other professional forums, suggests that earlier guidance limiting CTP utilization in SNFs may no longer be explicitly stated on the NGS website. It remains unclear when the change occurred or whether it reflects a deliberate policy shift, a temporary modification, or routine website maintenance. However, the Wound and Hyperbaric Association notes their advocacy, along with that of Congressman Pete Sessions (R, TX) as contributing to the reported removal.1
If confirmed, the removal of such language could carry meaningful implications for wound care providers operating in SNF and long-term care environments. Historically, uncertainty around CTPs use in POS 32 has influenced site-of-care decisions, documentation practices, and product utilization strategies—particularly for mobile wound care providers and groups serving post-acute populations.
The timing of the reported update is notable. It emerges amid broader Medicare reimbursement discussions affecting CTPs, including recent payment reforms and ongoing debates around access, utilization, and cost containment.
At present, stakeholders are advised to proceed cautiously. In the absence of formal communication or updated policy documentation from NGS, the reported change should not be interpreted as definitive regulatory direction.
Further clarification from NGS or CMS may be needed to determine whether this development represents a substantive shift in policy or simply a change in how existing guidance is presented.
- Wound & Hyperbaric Association. CAMPS advocacy matters patients matter […]. LinkedIn. Published April 4, 2026. Accessed April 5, 2026. https://www.linkedin.com/posts/wound-and-hyperbaric-association_camps-advocacymatters-patientsmatter-activity-7446300584502235136-OblJ
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