September 5, 2025
Kerecis Intact Fish Skin Grafts: Documentation and Coding Considerations
Overview of Kerecis Intact Fish Skin Grafts
Kerecis, is the company pioneering the use of sustainably sourced fish skin in cellular therapy and tissue regeneration. In total, nearly 200 million people in the United States are now covered under commercial insurance plans that recognize fish skin grafts as medically necessary for chronic wound care.
Clinical Use of Fish Skin Grafts in Tissue Regeneration
According to the Kerecis website, this graft “promotes healing with minimal impairment of functionality and positive cosmetic outcomes. The product is homologous to human skin and when applied to damaged tissue such as burns or wounds, helps top support the body’s own cells to regenerate tissue.”
Coding Clinic has released official guidance regarding Kerecis graft application in the fourth quarter of 2024. Their guidance tells us to report this application as replacement of skin with nonautologous tissue, full thickness, external approach. ( ICD-10-CM/PCS Coding Clinic, Fourth Quarter ICD-10 2024 Page: 65)
CMS Coverage and Diagnosis Reporting Requirements
CMS has released an LCD regarding the covered diagnosis for this unique skin regeneration. This procedure requires a dual diagnosis requirement. When reporting E08.621, E09.621, E10.621, E11.621, E13.621, one of the following must be reported with it to identify the site and severity of the ulcer: L97.411, L97.412, L97.415, L97.416, L97.421, L97.422, L97.511, L97.512, L97.515, L97.516, L97.521, L97.522, L97.525, or L97.526.
Liz Burson, BS, CCS
Senior Consultant, Audit at UASI
Liz Burson serves as a Senior Consultant in Auditing at UASI, with 20+ years of outpatient and inpatient coding experience. She provides coding tips based on current audit findings to help coders improve their accuracy in capturing the correct ICD-10-CM and PCS codes.
Works Cited:
American Hospital Association. (2024). ICD-10-CM/PCS Coding Clinic, Fourth Quarter, 65.
Centers for Medicare & Medicaid Services. (n.d.). Local Coverage Determination (LCD): Skin substitute grafts/cellular and tissue-based products for the treatment of diabetic foot ulcers and venous leg ulcers (L36377).
Available at
https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdid=36377
Centers for Medicare & Medicaid Services. (n.d.). Billing and coding: Skin substitute grafts/cellular and tissue-based products for the treatment of diabetic foot ulcers and venous leg ulcers (A57680).
Available at
https://www.cms.gov/medicare-coverage-database/view/article.aspx?articleId=57680
Kerecis. (n.d.). Intact fish skin for tissue regeneration.
Available at
https://www.kerecis.com













