CMS spent over $10 billion on skin substitutes in 2024, more than double 2023’s total and nearly 10 times 2022’s, prompting heightened scrutiny. Under the proposed 2026 Medicare Physician Fee Schedule, CMS plans to replace ASP + 6% reimbursement with a flat rate of approximately $800 per square inch, aiming for a 90% spending reduction.
In Medical Economics, Frier Levitt partner Guillermo Beades explores this shift in his article, “The 2026 Medicare Physician Fee Schedule Marks a Watershed Moment for Wound Care and Skin Substitutes.” He explains that while the change is intended to curb costs, standardize billing, and tighten utilization oversight, it could jeopardize the financial viability of in-office wound care programs, particularly in rural areas. This raises concerns about patient access.
With increased oversight expected, CMS and audit contractors will likely target high-utilization providers. Importantly, documentation gaps or insufficient clinical justification could result in significant overpayment demands and recoupments. This proposal signals a broader move toward value-based reimbursement, coupled with greater enforcement and future audits.
