APMA Opposes CMS' Proposals Related to Skin Substitutes, Efficiency Adjustment, and More in Response to the CY2026 MPFS Proposed Rule

APMA submitted comments to the Center for Medicare and Medicaid Services (CMS) in response to the proposed Medicare Physician Fee Schedule (MPFS) for Calendar Year 2026. APMA expressed appreciation for some of CMS' proposals, including an estimated 4 percent payment increase for podiatry, maintenance of the MIPS performance threshold, and the increased RVUs for arthrodesis codes CPT 28755 and 28750.

However, APMA expressed strong opposition to proposals related to the following:

Skin Substitute Payment Policy

APMA appreciates CMS' concern with increasing reimbursement for skin substitutes, given the nearly 40-fold increase in spending that CMS reports between 2019 and 2024. APMA agrees that reform is necessary; however, APMA believes that CMS' proposals have significant flaws that will cause unintended consequences for patients with wounds and the physicians who treat them. Therefore, APMA strongly urged CMS not to finalize its skin substitute proposals and instead work with stakeholders and Congress to develop a more reasonable and sound payment methodology that protects access to skin substitutes for Medicare beneficiaries.

Proposed Efficiency Adjustment

APMA opposes CMS' proposal to decrease the work RVUs and/or physician intra-service time for 7,267 physician services by 2.5 percent based on the assumption that efficiencies in physician time over the past five years justify a payment decrease. This proposal is arbitrary in application and would be exceedingly difficult to sustain with any accuracy to practical realities.

APMA also highlighted a number of opportunities for CMS to address burden reduction and improve care for patients with chronic diseases like diabetes. First, APMA recommended that CMS adopt separate coding and payment for a Comprehensive Diabetic Lower Extremity Exam (CDLEE) service, including, as necessary, through CMS Innovation Center authority.

Second, APMA continued to urge CMS to address the barriers that limit access to therapeutic shoes for Medicare beneficiaries with diabetes by simplifying documentation requirements and eliminating the co-signing requirement, enhancing clarity around regulatory compliance, and incentivizing provider participation.

Finally, APMA continued to recommend that CMS update its policy to allow for the use of the 59 and X{EPSU} Modifiers when pre-ulcerative calluses are pared on separate anatomic areas of the same toe that receive a nail debridement. The current National Correct Coding Initiatives (NCCI) policy limits the ability of physicians to perform both a callus paring and nail debridement on the same toe on the same visit. Removing this barrier would improve patient care and ensure providers receive fair and equitable reimbursement for their services.

To read this letter and APMA's comments in full, please visit https://www.apma.org/commentletters. Contact the APMA Advocacy Department with any questions or concerns.

Read APMA's analysis of the proposed MPFS here.