CMS Announces New Skin Substitute Payment Methodology: Possible Next Steps
Summary: CMS finalized the 2026 Physician Fee Schedule with a volume-weighted average payment of $127.28 per square centimeter for skin substitute products under Medicare Part B (non-facility and HOPD professional fees). Based on Q4 2024 ASP data, it addresses a 40-fold payment increase over five years. Biologicals under section 351 retain ASP reimbursement; no impact on WISeR or DFU/VLU LCDs. Providers should review ASP Pricing Files for product-specific limits to guide selection.
Key Highlights:
- Rate: $127.28/cm² for most substitutes; separate application reimbursement.
- Scope: Part B non-facility/HOPD; uses OPPS utilization for weighting.
- Exceptions: Section 351 biologicals (ASP); all 361 HCT/Ps included.
- Implications: Many products remain viable; check limits via HCPCS in ASP files.
- Next: Review files at cms.gov; non-Medicare payers may follow.
Keywords: CMS skin substitutes, 2026 PFS, DFU LCDs, VLU coverage, reimbursement