As APMA previously shared, CMS released the Medicare Physician Fee Schedule for Calendar Year 2026 proposed rule. A summary of the proposed rule and further analysis conducted by APMA is now available here.
Of particular note, CMS proposes to pay for skin substitute products as incident-to supplies when they are used as part of a covered application procedure paid under the PFS in the non-facility setting or under the OPPS in the hospital outpatient department setting. CMS also proposes to align skin substitute categorization consistent with their FDA regulatory status, such as 361 Human Cells, Tissues, Cellular and Tissue-Based Products (HCT/P), and the device types.
APMA is completing a thorough evaluation of the proposed rule and developing comments that will be sent to the agency by its deadline of September 12, 2025. Contact the APMA Advocacy Department with any questions or concerns.