CTP usage by site of care is not a footnote in real-world evidence, it is a primary axis of variation that national claims averages routinely flatten. A skin substitute that dominates volume in hospital-based wound centers may barely register in SNFs or home health, and the reasons have less to do with clinical preference than with reimbursement mechanics, coverage policy, and who is capturing the data in the first place. For manufacturers building PMCF files, payers testing formulary assumptions, and IDN value analysis committees comparing outcomes, treating site of care as noise rather than signal produces conclusions that don’t hold up once you stratify the data.
Why Does Site of Care Change CTP Utilization Patterns?
The single biggest driver is reimbursement structure, and that structure changed fundamentally on January 1, 2026. Under the CY 2026 Physician Fee Schedule and OPPS final rules, CMS reclassified most skin substitutes from biologicals paid at ASP + 6% to separately payable “incident-to supplies,” paid at a single national rate of $127.14 per square centimeter in both the hospital outpatient department and the physician office. In the HOPD, products were unpackaged from the application APC and assigned status indicator S1 across three new APCs based on FDA regulatory pathway; the low-cost C-codes C5271–C5278 were deleted, and the add-on application codes 15272, 15274, 15276, and 15278 remain packaged. Products licensed as biologics under Section 351 of the Public Health Service Act are the exception and continue to be paid under ASP methodology.
The practical effect is that the old site-of-care spread has largely collapsed. Every setting paid under the new methodology now absorbs product cost above a fixed amount, which gives every site a direct financial incentive to select lower-cost CTPs or to limit application frequency, regardless of clinical preference. Settings still operating under true bundles, most notably SNFs under Part A consolidated billing, where CTP cost falls into the per-diem, face the same pressure through a different mechanism. Anyone modeling site-of-care behavior on pre-2026 economics is modeling a market that no longer exists, a point worth tracking closely as the policy plays out.
MAC jurisdiction compounds this, though not in the way most industry summaries assume. On December 24, 2025, CMS announced that the A/B MACs were withdrawing the unified Local Coverage Determinations for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers that were to take effect January 1, 2026, the policies that would have sorted products into covered, non-covered, and MAC-discretion lists. What remains is a patchwork: Novitas, First Coast, and CGS retain their existing skin substitute policies, while Palmetto, NGS, WPS, and Noridian have no skin substitute LCD at all, leaving coverage to case-by-case reasonable-and-necessary determination. A DFU treated in one jurisdiction may therefore face materially different documentation and coverage expectations than the identical wound type treated two states over. Because this landscape has now shifted three times in three years, any claim about “the covered products” for a given wound type should be checked against the current, dated policy for the applicable MAC rather than assumed static.
Wound acuity and comorbidity burden also correlate with site of care in ways that are easy to overlook. Hospital-based wound centers disproportionately see refractory DFUs and VLUs referred after failed conservative therapy elsewhere, patients with more advanced peripheral arterial disease, and cases requiring debridement or offloading protocols that community settings are less equipped to manage. That case-mix skew means hospital-based utilization data reflects a sicker population by default, and comparing raw application rates or product selection across sites without adjusting for this acuity gradient will overstate or understate effectiveness differences that are really acuity differences. This is precisely the problem registry-based real-world data was built to solve, since the patients who drive the most CTP volume are the ones routinely excluded from the trials that established the products.
Put together, these three forces mean that a national utilization percentage for any given CTP is really an average across settings with different residual economics, different coverage expectations, and different patients. That average tells you very little about what is actually happening in any one setting.
Which CTPs Are Used Most in Hospital-Based Wound Centers?
Hospital-based wound centers carry the greatest product diversity of any site of care and the deepest structured clinical documentation, which is why they function as the primary source for comparative effectiveness work and leaderboard-style ranking reports. They are not necessarily the highest-volume setting: HHS OIG found that Part B spending on skin substitutes in non-institutional settings exceeded $10 billion in 2024, with patients treated at home accounting for roughly 28% of patients but more than half of spending by the third quarter of 2024. What hospital-based centers offer is breadth of formulary and the clinical context that makes utilization data interpretable.
Within that environment, product choice has historically been driven more by clinical protocol, facility formulary decisions, and physician preference than by unit cost. Under the 2026 flat rate, that is changing quickly. Any product with an acquisition cost above $127.14 per square centimeter is now a margin loss in the HOPD, which means facility value analysis committees are re-running formulary math that had been stable for a decade. The setting that once tolerated the widest price range is now the one with the most active repricing.
One pattern manufacturers should track closely is how quickly product mix shifts after a payment or coverage change. When a MAC changes its coverage posture, or when a payment methodology resets as it did this year, hospital-based wound center utilization data tends to move within a reporting cycle or two, well ahead of what shows up in lagging claims files. That makes site-stratified, near-real-time utilization tracking, the kind captured in a platform like Intellicure’s Wound Care Industry Dashboard, a leading indicator of share movement rather than a historical record. A manufacturer relying solely on quarterly or annual claims summaries to detect a payment-driven share shift is typically several months behind the actual clinical reality on the ground.
This is also where Product Ranking Reports become useful for competitive intelligence: because hospital-based centers carry the deepest product diversity, a site-specific leaderboard for this setting reveals which competitors are actually gaining or losing share in the most formulary-diverse channel, as opposed to national rankings that blend in settings where a product may not even be a realistic option.
How Does CTP Usage Differ in SNFs and Home Health Settings?
Product selection in SNFs and home visit settings is narrower, and for structural reasons rather than clinical ones. Facility formularies in skilled nursing settings often restrict CTP options to a small number of products, driven by contracting arrangements, staff training on application technique, and logistics around cold-chain storage or single-use packaging that are harder to manage outside an institutional wound center. A product that requires precise reconstitution, tight storage windows, or specialized handling is simply less practical in a setting without dedicated wound care staff on every shift.
Application frequency and total graft counts per wound episode also vary meaningfully across settings. This has direct implications for comparative effectiveness study design: if a study pools healing outcomes across sites of care without adjusting for differences in applications per episode, any observed difference in healing rates could reflect dosing intensity and setting constraints rather than product performance. Risk adjustment for site of care should be treated as standard practice in this kind of research, not an optional refinement.
Home health data is a different problem than it is usually described as being. Volume is not the issue; OIG’s analysis made home-setting billing highly visible, and the disproportionate growth in home claims is exactly what drove the 2026 payment reform. The gap is granularity. A CTP applied during a home visit is billed under Part B by the treating practitioner, but the encounter-level detail needed to link that application to a specific wound etiology, wound measurement, healing trajectory, or comparative product context is frequently absent from the data researchers and manufacturers typically access. The practical effect is that home and mobile CTP use is under-characterized rather than undercounted: you can see that it happened, but not to what wound, in what patient, with what result.
What Data Gaps Distort Site-of-Care Comparisons?
Aggregate claims data, including Medicare Part B and OPPS files, reports HCPCS-level volume with reasonable reliability, but it rarely links a specific product choice to wound-specific outcomes, wound etiology, or site-level clinical context. You can see that a given CTP code was billed a certain number of times in a given quarter; you generally cannot see, from that file alone, what wound type it was applied to, how the patient responded, or what alternative products were considered and rejected at that site. That gap limits how much causal weight any single claims-based finding can bear, and it is the reason structured point-of-care documentation produces a fundamentally different class of evidence than billing data does.
Site-of-care coding inconsistencies add another layer of distortion. Off-label applications, non-billed product use in bundled settings, and inconsistent place-of-service coding all mean that reported utilization in some settings understates actual product use. A SNF that absorbs CTP cost into a per-diem rate has little administrative incentive to code product use with the same specificity as a hospital outpatient department billing a separately payable supply, which means the reported gap between hospital-based and SNF utilization is probably wider in the data than it is in practice.
The practical guidance for anyone using this kind of data in a PMCF file, a payer dossier, or an investor diligence memo is straightforward: any specific utilization percentage or site-of-care ranking cited in a report should be traceable to a named, dated data source, not treated as a stable national average. Regional coverage variation and payer mix differences mean the true figure for a given MAC jurisdiction or IDN can diverge materially from whatever number appears in a general industry summary. Verify before you build a strategy on it.
How Should Manufacturers and Payers Act on Site-of-Care Data?
For manufacturers, site-stratified real-world data serves two distinct purposes. It supports PMCF obligations by documenting how a product actually performs and gets used across the settings where it’s approved for use, which is a stronger evidentiary base than single-setting registry data. It also reveals competitive dynamics that aren’t visible from a national vantage point: a product might be winning share steadily in hospital-based wound centers while losing ground in SNFs to a competitor the brand team isn’t even tracking, because the commercial team has been benchmarking against the wrong comparator set for that setting.
Market access teams should resist the reflex to interpret low utilization in a given region or setting as evidence of a demand problem before checking payment and MAC policy status. A product with genuinely strong clinical uptake can show flat or declining utilization simply because its acquisition cost sits above the national payment rate in that setting, or because the local MAC’s documentation posture makes it harder to support. Pairing utilization trend data with active coverage and payment tracking prevents misdiagnosing a reimbursement problem as a clinical or commercial one, and vice versa. With the MACs expected to revisit skin substitute coverage once the current status quo period ends, this is not a one-time reconciliation.
IDN value analysis committees and payers face a parallel version of this problem when evaluating formulary decisions. A single-setting pilot, often run in one hospital-based wound center, cannot answer the question of how a product will perform once it moves into SNF or home health use within the same network. Comparative, site-specific utilization and outcomes data lets these committees test formulary assumptions against actual cross-setting performance rather than extrapolating from a pilot population that doesn’t represent the full range of care settings where the product will eventually be used.
Treating Site of Care as a Modeling Variable, Not an Afterthought
The consistent theme across hospital-based wound centers, SNFs, and home health is that site of care shapes product selection, dosing frequency, and even what the data can tell you in the first place. Any comparative effectiveness study, PMCF report, or formulary decision that ignores this variable is working with a distorted picture, whether it’s overstating differences driven by acuity mix or understating true utilization in settings with weaker data capture. The fix isn’t more national averaging, it’s site-stratified tracking that lets you see what’s actually happening in each setting on its own terms.
Intellicure Analytics builds its Wound Care Industry Dashboard and Product Ranking Reports around exactly this kind of stratification, tracking CTP utilization separately across hospital-based wound centers, SNFs, and home visits rather than collapsing them into a single national figure. That data is drawn from structured point-of-care documentation and the US Wound Registry, a CMS-recognized Qualified Clinical Data Registry, rather than reconstructed from billing files. For manufacturers, payers, and IDN purchasers who need defensible, current, site-specific data rather than assumptions extrapolated from claims averages, Learn more about our services.