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The rules say that plans must pay for a medical service or item if regular Medicare would pay for it in this case. 
You can find this rule at 42 Code of Federal Regulations (CFR) Section 422.101. 
 
The rules say that the addition of Skin Substitutes or Cellular or Tissue Based Products (CTPs) to certain 
wounds may afford a healing advantage over dressings and conservative treatments when these options appear 
insufficient to affect complete healing. 
 
There are currently a wide variety of bioengineered products available for soft tissue coverage to affect closure. 
These products may be derived from allogeneic, xenogeneic, synthetic sources or a combination of any or all of 
these types of materials. However, without the component of the recipients own distinct epithelium and 
cellular skin elements, permanent skin replacement or coverage by the graft cannot be accomplished. 
 
Autologous skin grafts, also referred to as autografts, are permanent covers that use skin from different parts of 
the individuals body. These grafts consist of the epidermis and a dermal component of variable thickness. A 
split-thickness skin graft (STSG) includes the entire epidermis and a portion of the dermis. A full thickness 
skin graft (FTSG) includes all layers of the skin. Although autografts are the optimal choice for full thickness 
wound coverage, areas for skin harvesting may be limited, particularly in cases of large burns or venous stasis 
ulceration. Harvesting procedures are painful, disfiguring and require additional wound care. 
 
Allografts which use skin from another human (e.g., cadaver) and Xenografts which use skin from another 
species (e.g., porcine or bovine) may also be employed as temporary skin replacements, but they must later be 
replaced by an autograft or the ingrowth of the patients own skin. 
 
Bioengineered Skin / Cultured Epidermal Autografts (CEA) are autografts derived from the patients own skin 
cells grown or cultured from very small amounts of skin or hair follicle. Production time is prolonged. One 
such product is grown on a layer of irradiated mouse cells, bestowing some elements of a xenograft. 
Widespread usage has not been available due to limited availability or access to the technology. 
 
Bioengineered Skin Substitutes or Cellular and Tissue Based Products (CTPs), referred to as Skin Substitutes 
by CMS, The Current Procedural Terminology (CPT) and The Healthcare Common Procedure Coding 
Manuals, have been developed in an attempt to circumvent problems inherent with autografts, allografts and 
xenografts. These constitute biologic covers for refractory wounds with full thickness skin loss secondary to 3rd degree burns or other disease processes such as diabetic neuropathic ulcers and the skin loss of chronic 
venous stasis or venous hypertension. The production of these biologic skin substitutes or CTPs varies by 
company and product, but generally involves the creation of immunologically inert biological products 
containing protein, hormones or enzymes seeded into a matrix which may provide protein or growth factors 
proposed to stimulate or facilitate healing or promote epithelization. A variety of biosynthetic and tissue-
engineered skin substitution products marketed as Human Skin Equivalents (HSE) or Cellular or Tissue-based 
Products (CTP) are manufactured under an array of trade names and marketed for a variety of indications. All 
are procured, produced, manufactured, processed and promoted in sufficiently different manners to preclude 
direct product comparison for equivalency or superiority in randomized controlled trials. Sufficient data is 
available to establish distinct inferiority to human skin autografts and preclude their designation as skin 
equivalence. 
 
Bioengineered skin substitutes or CTPs are classified into the following types: 
 
Human skin allografts derived from donated human skin (cadavers) 
Allogeneic matrices derived from human tissue (fibroblasts or membrane) 
Composite matrices derived from human keratinocytes, fibroblasts and xenogeneic collagen 
Acellular matrices derived from xenogeneic collagen or tissue 
Human Skin Allografts are bioengineered from human skin components and human tissue which have had 
intact cells removed or treated to avoid immunologic rejection. They are available in different forms promoted 
to allow scaffolding, soft tissue filling, growth factors and other bioavailable hormonal or enzymatic activity. 
 
For the purpose of this LCD, consideration is given to the use of dermal or epidermal substitute tissue of 
human or non-human origin, with or without bioengineered or processed elements, with or without 
metabolically active elements, with a designated use as coverage for a superficial skin deficit that has persisted, 
despite optimal wound care for a period of 4 weeks or greater. These products are those referred to as Human 
Cellular or Tissue Based Products (CTPs) or Skin Substitutes. 
 
You can find these rules in the Local Coverage Determination (LCD) Application of Bioengineered Skin 
Substitutes to Lower Extremity Chronic Non-Healing Wounds L35041. 
 
If you want to read these Medicare rules, you can go to this website www.medicareappeal.com. 
 
The Plan contract says that the Plan covers items and services in accordance with Medicare rules.