Proposed CMS Rule May Eliminate Separate Payment for Skin Substitutes
In a recent blog post, Dr. Caroline Fife examines the Centers for Medicare & Medicaid Services’ (CMS) 2025 Proposed Physician Fee Schedule, which includes a significant shift in how cellular and/or tissue-based products for skin wounds (CTPs) may be reimbursed. The rule proposes to package payment for skin substitutes into the procedure code itself, effectively ending separate reimbursement for these materials under Medicare Part B in the office setting.
Key Points:
- Background: The CMS rule would bundle skin substitute payments with provider fees, similar to the current hospital outpatient payment model. This change would apply to physician offices, not just hospital settings.
- Concerns Raised: Dr. Fife warns this could reduce access to important wound healing products, particularly for providers without the financial resources to absorb upfront material costs.
- Stakeholder Impact: Many small practices and providers serving vulnerable populations may stop using CTPs altogether, which could worsen outcomes for patients with chronic wounds.
- Call to Action: Dr. Fife encourages clinicians and stakeholders to submit public comments to CMS before the September deadline and engage with their professional societies to ensure their voices are heard.
Conclusion: The proposed rule represents a major reimbursement shift with potentially far-reaching consequences for wound care delivery in physician offices. Advocacy and awareness are essential to protect access to these vital treatment tools.
Keywords: Caroline Fife, CMS, skin substitutes, Medicare, CTP, reimbursement, wound care policy