Medicare Part B MACs Withdraw Skin Substitute LCDs: What We Know and What Remains Unclear
Key Takeaways
1. CMS has withdrawn—not delayed—the 2026 skin substitute LCDs, leaving existing MAC coverage policies in place where they currently exist. As of December 24, 2025, CMS removed the Local Coverage Determinations for skin substitute grafts and cellular and tissue-based products that were scheduled to take effect January 1, 2026, without signaling a postponement or replacement timeline.
2. Medicare Part B coverage for skin substitutes will continue to vary by MAC, increasing documentation and compliance risk. Clinicians in Novitas, First Coast, and CGS jurisdictions should continue to follow current LCD requirements, while providers in other regions remain subject to “reasonable and necessary” determinations. This variability reinforces the need for careful alignment between clinical decision-making, coding, and payer-specific expectations.
3. Updated payment rates remain unchanged for 2026, but WISeR model implementation is now limited to fewer states. The finalized CMS payment rate of $127.14 per square centimeter for non-biological skin substitute products remains scheduled for January 1, 2026; however, WISeR prior authorization requirements will not take effect in states without an active LCD. Practitioners in New Jersey, Ohio, Oklahoma, and Texas should continue preparing for WISeR compliance, while providers elsewhere should monitor for future CMS guidance.
Updated January 2, 2025.
On the afternoon of December 24, 2025, CMS issued a press release stating, “effective immediately, CMS’ A/B Medicare Administrative Contractors (MACs) are withdrawing the Local Coverage Determinations (LCDs) for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers that were scheduled to become effective on January 1, 2026.”1 The press release announcing this change did not use either the term “delayed” or “postponed.”
Medicare Part B Coverage
While Medicare is a national program, it is administered on a local level by Medicare Administrative Contractors (MACs). MACs can choose to issue Local Coverage Determinations (LCDs) and LCD Reference Articles for certain services. LCDs and LCD Reference Articles typically outline the documentation requirements, coverage allowances, and coverage limitations for a service. There are seven Part B MACs in the country. Different Part B MACs may have different coverage policies for the same service. The identity of the seven Part B MACs and their jurisdictions are as follows.
First Coast Service Options2:
• Florida
• Puerto Rico
• Virgin Islands
Palmetto GBA3:
• Alabama
• Georgia
• Tennessee
• South Carolina
• Virginia
• West Virginia
• North Carolina
Outside of the above-referenced, previously future-effective LCDs, only three of these Part B MACs currently have active coverage policies for skin substitute services: Novitas, First Coast, and CGS. All three of these existing policies were scheduled to be retired on December 31, 2025 with the new policies taking effect on January 1, 2026. With the withdrawal of the policies that were scheduled to become effective on January 1, 2026, those December 31, 2025 retirement dates have been removed and the Novitas, First Coast, and CGS skin substitute policies will remain effective with no changes. The other four Part B MACs will continue to not have any published coverage policy for skin substitute application. In the absence of such a policy, the Part B MAC determines coverage based on their assessment of the service being “reasonable and necessary.”
Novitas Solutions, Inc4:
• Colorado
• New Mexico
• Oklahoma
• Texas
• Arkansas
• Louisiana
• Mississippi
• Delaware
• Washington DC
• Maryland
• New Jersey
• Pennsylvania
NGS, Inc5:
• Illinois
• Minesota
• Wisconsin
• Connecticut
• New York
• Maine
• Massachusetts
• New Hampshire
• Rhode Island
• Vermont
CGS Administrators, LLC6:
• Kentucky
• Ohio
WPS Ins Corp7:
• Iowa
• Kansas
• Missouri
• Nebraska
• Indiana
• Michigan
Noridian Healthcare Solutions, LLC8:
• Alaska
• Idaho
• Oregon
• Washington
• Arizona
• Montana
• North Dakota
• South Dakota
• Utah
• Wyoming
• California
• Hawaii
• Nevada
Will the Payment Rate Change?
At the moment, the withdrawal of these policies has no impact on the CMS finalized payment rate of $127.14 per sq cm for all non-biological skin substitute products for all indications. This is still scheduled to take effect January 1, 2026.9
WISeR
At the moment, the only impact the withdrawal of these policies has on the WISeR model is that the skin substitute component of the WISeR model will not take effect in Arizona and Washington on January 1 because there will be no active LCD for the service in those states. This leaves only four states where the WISeR model is still scheduled to be in effect for skin substitute application to diabetic foot ulcers and venous leg ulcers for Medicare Part B beneficiaries performed in certain sites of service: New Jersey, Ohio, Oklahoma, and Texas.10,11
Dr. Lehrman is a podiatrist and a Certified Professional Coder and Certified Professional Medical Auditor. He operates Lehrman Consulting, LLC, which provides guidance regarding coding, compliance and documentation. Dr. Lehrman serves as a staff liaison at the AMA CPT® Editorial Panel meetings where CPT codes are created, edited, and deleted.
References
1. Centers for Medicare & Medicaid Services. Final local coverage determinations (LCDs) for certain skin substitutes withdrawn. Published December 24, 2025. Accessed December 24, 2025. https://www.cms.gov/newsroom/fact-sheets/upcoming-update-final-local-coverage-determinations-lcds-certain-skin-substitutes
2. First Coast Service Options, Inc. Accessed December 24, 2025. https://medicare.fcso.com
3. Palmetto GBA. Accessed December 24, 2025. https://palmettogba.com
4. Novitas Solutions, Inc. Accessed December 24, 2025. https://www.novitas-solutions.com/webcenter/portal/NovitasSolutions
5. National Government Services, Inc. Accessed December 24, 2025. https://www.ngsservices.com
6. CGS Administrators, LLC. Accessed December 24, 2025. https://www.cgsmedicare.com/partb
7. WPS Government Health Administrators. Accessed December 24, 2025. https://www.wpsgha.com
8. Noridian Healthcare Solutions, LLC. Accessed December 24, 2025. https://med.noridianmedicare.com
9. Medicare and Medicaid Programs; CY 2026 payment policies under the physician fee schedule and other changes to Part B payment and coverage policies; Medicare Shared Savings Program requirements; and Medicare Prescription Drug Inflation Rebate Program. 42 CFR Parts 405, 410, 414, 424, 425, 427, 428, 495, and 512 (CMS-1832-F); RIN 0938-AV50.
10. Medicare Program; implementation of prior authorization for select services for the wasteful and inappropriate service reduction (WISeR) model. Fed Register. Published July 1, 2025. Accessed September 15, 2025. https://www.federalregister.gov/documents/2025/07/01/2025-12195/medicare-program-implementation-of-prior-authorization-for-select-services-for-the-wasteful-and
11. Centers for Medicare & Medicaid Services. Wasteful and Inappropriate Service Reduction (WISeR) Model provider and supplier operational guide. Version 2.0. https://www.cms.gov/files/document/wiser-provider-supplier-guide.pdf
Additional Resources on the WISeR Updates
12. Centers for Medicare & Medicaid Services. Medicare program; implementation of prior authorization for select services for the Wasteful and Inappropriate Services Reduction (WISeR) Model. Fed Regist. 2025;90(124). Pages 28750 and 28751. Published July 1, 2025. Accessed January 2, 2026. https://www.govinfo.gov/content/pkg/FR-2025-07-01/pdf/2025-12195.pdf
13. Centers for Medicare & Medicaid Services. Medicare Program; Implementation of Prior Authorization for Select Services for the Wasteful and Inappropriate Services Reduction (WISeR) Model. 90 FR 28749-28753. Fed Regist. July 1, 2025. Accessed January 2, 2026. https://www.federalregister.gov/documents/2025/07/01/2025-12195/medicare-program-implementation-of-prior-authentication-for-select-services-for-the-wasteful-and
14. Center for Medicare and Medicaid Innovation. WISeR Model Office Hour [video]. YouTube. Minute 33:30. Published July 17, 2025. Accessed January 2, 2026. https://www.youtube.com/watch?v=CATxta1fFu4
15. Centers for Medicare & Medicaid Services. Medicare Program; Implementation of Prior Authorization for Select Services for the Wasteful and Inappropriate Services Reduction (WISeR) Model. 90 FR 28749-28753. Fed Regist. July 1, 2025. Accessed January 2, 2026. https://www.federalregister.gov/documents/2025/07/01/2025-12195/medicare-program-implementation-of-prior-authorization-for-select-services-for-the-wasteful-and
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