CMS Announces New Skin Substitute Payment Methodology: Possible Next Steps
Summary: The Centers for Medicare & Medicaid Services (CMS) finalized a new payment model for skin substitute products under the 2026 Medicare Physician Fee Schedule, effective for Medicare Part B beneficiaries in non-facility and hospital outpatient settings. Payment for most skin substitutes will be a volume-weighted average of $127.28 per square centimeter, based on fourth-quarter 2024 data, while biologicals licensed under section 351 continue using the average sales price (ASP) methodology. This change does not affect the WISeR model or Part B MAC coverage policies for diabetic foot ulcers (DFUs) and venous leg ulcers (VLUs), set for January 1, 2026. Providers can access ASP pricing files to review product-specific payment limits, many below the average, to inform product selection. Non-Medicare payers may adopt or adapt this methodology.
Key Highlights:
- New payment model sets volume-weighted average of $127.28 per square centimeter for skin substitutes in 2026.
- Exception for biologicals licensed under section 351, which retain ASP payment methodology.
- Payment based on volume-weighted ASP from Q4 2024, using OPPS data for utilization proportions.
- No impact on WISeR model or MAC coverage criteria for DFUs and VLUs effective January 1, 2026.
- Providers can check CMS ASP Pricing Files for product-specific payment limits to guide decisions.
Keywords: skin substitutes, Medicare payment, diabetic foot ulcers, venous leg ulcers, Physician Fee Schedule