2026 Physician Fee Schedule proposal would standardize payment for all “skin substitutes”

2026 Physician Fee Schedule proposal would standardize payment for all “skin substitutes”
Jan 08, 2025
Centers for Medicare & Medicaid Services (CMS) — Proposed Rule (summarized by policy analysts)
4 min read
Policy & Reimbursement

In the CY 2026 Physician Fee Schedule Proposed Rule, CMS outlines a single national payment rate (~$125.38/cm²) and shifts certain skin-substitute payments to incident-to supplies, changes that could reshape pricing dynamics for placental allografts in physician offices.

Mid-July 2025, policy analysts highlighted CMS’s proposed CY 2026 changes for physician-office use of skin substitutes, including a uniform per-cm² rate (~$125.38) and treating these products as incident-to supplies. While still proposed (not final), the policy aims to curb spending variability and could narrow price differentials among products—especially relevant for placental allografts (amnion/chorion, umbilical cord matrices). If finalized, clinics may re-evaluate product selection based on clinical evidence, handling characteristics, and outcomes rather than price dispersion alone. Stakeholders should monitor the rulemaking process and submit comments before finalization.

Tags: CMS Physician Fee Schedule Reimbursement Incident-to Skin Substitutes Placental Allografts Policy Proposal

Let's Build Healthier Solutions Together

Get in touch with our team to discuss your healthcare needs