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The Skin Sub Overage Paradox

These 32 pages of charts, data, and analysis show how and why the 2026 skin sub payment ruling affected overage in an unexpected way.

More than 15,000 CTP applications, each one measured against the wound it treated. What the 2026 payment reset actually did to product sizing, and why the cause sits upstream of the clinician.

A Medicare claim records what was billed. It does not record how big the wound was. That gap is why nobody — not CMS, not manufacturers, not the practices under audit — has been able to say how product size actually compares to wound size in real practice.

The Skin Sub Overage Paradox puts a year and a half of non-HOPD applications against a single question: how big was the product, and how big was the wound?

The answer is not the one the fraud-and-abuse coverage would predict.

Wound Care Product Manufacturers: Your size range may be shaping your customers’ overage profile and their audit exposure in ways your sales data cannot show you.

Payers and policy teams: Why a fixed percentage threshold fails at both ends of the wound-size range, and what a measurement-based alternative would look like.

Legal and compliance: Sizing has become an audit exposure the clinician cannot fully control. The report explains the mechanism and where the defensible ground is.

Investors and analysts: Eight falsifiable readings of what the post-reset market is signaling, starting with formulary contraction.

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