APMA continues its strong opposition to the Centers for Medicare & Medicaid Services (CMS) Wasteful and Inappropriate Service Reduction (WISeR) Model. Last week, APMA directly contacted the Center for Medicare and Medicaid Innovation, calling on CMS to remove CPT® 11042 (Debridement subcutaneous tissue, first 20 square cm) from Appendix B of the WISeR Model Provider and Supplier Operational Guide.
APMA's letter explains that CPT® 11042 was inappropriately listed as an "associated" service, by National Correct Coding Initiative procedure-to-procedure edits, for skin substitute application. Under current Medicare rules, CPT® 11042 and skin substitute application codes (CPT® 15271–15278) should only appear together on the same claim when performed for separate, unrelated issues, not when performed for the same wound. As written, the WISeR Model would restrict coverage for ulcer debridement that is medically necessary, unrelated to skin substitute application, and considered standard of care for chronic wounds.
APMA emphasized that ulcer debridement is an essential element of proper wound management and extensive peer-reviewed evidence shows ulcer debridement improves healing outcomes, reduces infection risk, and can prevent amputation. APMA urged CMS to revise the WISeR Model accordingly and remains committed to ensuring patient access to appropriate and necessary wound care. The letter reinforces APMA's ongoing role as a trusted clinical and policy resource for CMS.
For additional background and details on the WISeR Model, including APMA's extended video overview, visit APMA's WISeR Model Resource page. Contact the APMA Advocacy Department with any questions or concerns.