Implementation of Three Unexpected CTP 2026 Medicare Payment Changes: Part 1

• Medicare 2026, CTP sheets (US): Same allowable payment for all brands at $127.14 per square centimeter; product payment now separate from application in hospital outpatient PBDs; no high-/low-cost APC differentiation; use application codes 15271–15278 (remove C5271–C5278).

• Hospital PBDs: Update formularies to products ≤$127.14/cm² with published evidence; ensure correct Q/A HCPCS codes, chargemaster entries, separate product charges; align 15277 (DFU ≥100 cm²) charges with 15273 (VLU ≥100 cm²).

• ASCs and physicians/QHPs: ASCs paid ~40% of OPD (e.g., 15271: $746 OPD vs $404 ASC; 15275 DFU small: ~$94 ASC; large ulcers >100 cm² ~>$1,000). All sites must update EHR, coding, billing, and staff education.

Please note: This content is a direct transcript, capturing the authentic conversation without edits. Some language may reflect the flow of live discussion rather than polished text. 

Hello and welcome to the CTP News Desk. This is going to be a three-part series and it is entitled “Implementation of Three Unexpected CTP 2026 Medicare Payment Changes.” The first part is going to be the unexpected change was the same allowable payment rate for all brands of CTP sheets. The second part is going to be about the exceptions to the CTP Medicare payment of $127.14 per square centimeter. And the third part is going to be the unexpected change of no Medicare payment for CTP wastage. 
 
My name is Kathleen Schaum and I'm the founder and president of Kathleen D. Schaum and Associates. And I am excited to be here today with you because for about the last two years, I have been telling all of our professionals to be ready for major changes in the payment and coverage for CTPs. And there are a lot of people who did prepare and there are a lot of people who waited because there were others who would tell them, "Oh, nothing's going to change. Just keep on doing what you're doing." 
 
So at this moment, we have had changes. And so in this three-part series, I hope to share with you—you probably know what the change is, but most important, how do you implement it? 
 
So let's begin with the unexpected payment change number one. And that was that we are given the same allowable payment rate for all brands of CTP sheets. Now that means that you're probably having to do some refinement of your business model and your revenue cycle processes so that you can receive this new payment rate for all brands of the CTP sheets. So I'm going to talk to you about the three places of service or providers who do this work and how each segment will have to make some changes and what you should do. 
 
So let's first talk about the great news that we had for hospital-owned outpatient wound and ulcer management provider-based departments, better known as PBDs. Now, we know that the payment for the CTPs is no longer packaged into the Medicare payment for the application. And we also know that the PBDs will receive separate payment for all covered sheet CTPs. And that Medicare payment is the same for all brands, and it's $127.14 per square centimeter. Well, that's great, but what does that mean to you? That means to you, if you are in a provider-based department, you need to refine your formulary to include CTPs that have published evidence and whose costs are less than $127.14 per square centimeter. Also, because the CTPs products had been packaged into the application rate, there are many PBDs who didn't really keep track or even put into their chargemasters the correct HCPCS codes for the products. 
 
Now, it's very important that you have the correct Q code and A code that matches up to every product that you're going to keep in your formulary or add to your formulary in 2026. So don't assume that those codes are correct. It's extremely important for you go into your system and look and be sure you get the right codes for the products you are going to use. Also, because the products have been packaged into the application rate, you may not have into your system a charge for the product. So now it's very important for you to put a charge into your system for every single brand of CTP that you're going to use. 
 
And the most important part is keeping in mind that you had a charge for the application, but that charge was large because it included the charge for the product also. Now you have to reduce that charge for your application because you are going to be charging for the product and the application. So you cannot leave that product buried inside that application. 
 
We also know that the application codes are no longer differentiated by the cost of the CTP. So we don't have any more high-cost and low-cost application codes. We're only using 15271 to 15278. So in your charging system, you may have the codes for the application of low-cost CTPs, and those codes were C5271 to C5278. It's very important. You remove those from everything so that you don't make a mistake and report those codes. 
 
We also know that we have had a problem for multiple years when we wanted to apply a CTP to a diabetic foot ulcer that was 100 square centimeters or greater. And that payment rate that Medicare for some reason was paying us as if the ulcer was less than 25 square centimeters. So many of you may have a low charge in your system for the application code 15277, which is the code to apply to a large diabetic foot ulcer. It's important you look at your chargemaster and you make that charge be identical to the charge you're going to charge for the same size ulcer that's a venous ulcer on the leg. And that code would be 15273. So I am a betting woman that if you go into your system, many of you are going to see that you have a low charge for 15277 for the foot and a higher charge for the 15273 for the leg. Now you must increase your charge for the 15277 to equal that of 15273. 
 
So with all those things that I'm telling you to be sure to do, you have to start in your EHR and be sure your EHR has the right codes, has ability for you to report, and then you need to check your charge description master and then your coding and billing software. So even though this is great news that we have this new separate payment for the product, we have to make sure our systems are ready for it. 
 
So therefore, what do you have to do? You have to do a bit of education for your system. Remember that we're going to be asking to change our formularies if you haven't already done that. And so you may have to have a blessing from your executives to quickly add some additional or reduce some products off your formulary. And you have to tell them why, because you need to get below $127.14. Excuse me. Also, many executives have always capped how large of an ulcer you could take care of because you were not able to get paid for the extra product. So you need to educate your executives how you could now afford to manage larger wounds and ulcers. And then because you are going to be adding or subtracting products from your formulary and you're going to be doing it based on evidence, you need to share that evidence with your clinical staff because they need to put that into their documentation. And then finally, of course, you have to be sure everybody in the revenue cycle team knows the correct codes needs to know that the sheet products are all paid the same now, and there's no longer an assignment to a high cost or a low-cost APC. So you can see PBDs have some work to do if you haven't done it. 
 
Now, let's move to the ASCs for a moment. And if you were an ASC that is not owned by the hospital, we know that the ASCs most of the time have not been able to afford to apply a CTP because those ASCs get paid about 40% of what an outpatient department gets paid. So for example, in this year, 15271, the application to the leg, the outpatient department gets paid around $746, where the ASC gets paid $404. So when you look at that, many times, if the product was packaged inside of that, you could see that the ASC couldn't afford to do it, but now the ASC would get paid separately for the product, and so therefore they might be able to afford to do it.
 
I do want to bring to your attention though, one important thing: the codes for the application for the diabetic foot ulcer that is small, which is the code 15275, still has a very low application rate. For example, in the ASC for the leg, it's around $404 for the application, but for the same size ulcer on the foot, it's $94. So the ASCs may be able to afford to put on a diabetic foot ulcer since they get paid for the product separately, but they may also say, "No, we can't afford it for the diabetic foot ulcer, but we can afford it for the venous ulcer." Or now when you get back though to the diabetic and venous ulcer for wounds and ulcers greater than 100 square centimeters, both of the rates are back up and they're a little over $1,000. 
 
So next I want to talk to you about physicians in QHPs. They really need to examine their business models. And we know that the physicians and QHPs are now getting paid the same amount of money for all brands of CTP for the sheets and it's the same per square centimeter. So they have to do exactly the same as the outpatient department where they have to refine their formularies, they have to be sure they have the right codes in their system, they have to be sure they have the right charges. And of course, they have to update all of their EHRs, their CDMs, and their coding and billing software. And of course, then be sure that their staff knows about the clinical evidence for the products that they selected, knows the importance of documentation and that the revenue cycle team knows. And I've seen a lot of things on the internet that the coding and billing people that are doing work for the physicians seem not to be totally aware of exactly what went on with the CTPs for this year.
 
So in summary, I want to remind you that the Medicare payment system for CTPs and their application has changed. And the provider-based departments, the ASCs, the physicians, and the qualified healthcare professionals have to refine their product formularies. They have to refine their EHRs, their charges, and their charge description master, as well as their coding and billing system. And most of all, you have to educate your administration, your clinicians, your revenue cycle teams, so they all understand all the pieces and parts that need to be updated in order to implement this new payment system. 
 
And I want to thank you for allowing me to share tips for refining your revenue cycle processes to implement the 2026 Medicare payment changes for CTP sheets. But I want you to stay tuned for part two of this series when I will discuss the exceptions to the same payment rate for CTPs. Thank you very much.

Kathleen D. Schaum is a reimbursement strategy and education consultant to the wound/ulcer management industry. She has over 50 years of experience training professionals, executives, sales representatives, and investors how services, procedures, and products are reimbursed in various places of service.