Regulatory Update: Calendar Year 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F)
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On October 31, 2025, the Centers for Medicare and Medicaid Services (CMS) published their final rule with policy changes under the Physician Fee Schedule (PFS) and other issues related to Medicare Part B.1 This final rule includes information on a new payment model for skin substitute products applied in the private office and the professional component of those applied in the hospital-based outpatient department (HOPD) setting.
At present, most skin substitutes are reimbursed as biologicals with each product having a unique code that corresponds to a unique payment limit.1 Due to what CMS cites as a close to 40-fold increase in payments over five years, the final rule sets the payment for skin substitute products for Medicare Part B beneficiaries as $127.28 per square centimeter. It is important to note that CMS will continue to reimburse separately for the application and the product, and that the amount above reflects payment for the product. The only exceptions to this new rate are products truly classified as biologicals, which are those licensed under section 351 of the Public Health Service Act.1
The final rule cited above is set to go into effect on January 1, 2026.1 This final rule is does not impact the WISeR model, nor the future effective local coverage determinations (LCDs) for Part B Medicare Administrative Contractors’ (MACs’) coverage policies on skin substitutes for diabetic foot ulcers and venous leg ulcers, all also currently scheduled to take effect on January 1, 2026. Look for more insights from Podiatry Today and Wound Care Business Navigator on these policies as information develops.
Reference
1. Centers for Medicare and Medicaid Services. Fact Sheet: Calendar Year (CY) 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F). Published October 31, 2025. Accessed November 4, 2025. Available at: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule-cms-1832-f .
