CMS Issues Correction to Skin Substitute Provisions in Medicare Physician Fee Schedule

On November 28, CMS published a correction notice to the CY 2026 Medicare Physician Fee Schedule (MPFS), which included updates to the finalized payment rate for skin substitutes. In the notice, CMS clarified that it is finalizing a CY 2026 payment rate of $127.14 per square cm, aligning with the Hospital Outpatient Prospective Payment System (OPPS) rate in the preamble discussion.

However, APMA notes that the calculated rate in Addendum B of the MPFS Final Rule (derived by multiplying the total RVUs (3.81) by the Non-Qualifying APM Participant Conversion Factor of $33.4009) results in a slightly different amount of $127.26. Similar discrepancies were observed between reported and calculated rates in the proposed rule. Final payment amounts may also vary based on factors such as geographic adjustments, MIPS, sequestration, and other applicable modifiers.

To stay updated on APMA's coverage of new Medicare rules, visit our Medicare Resources page. For a deeper dive into changes to skin substitute coverage and payment, watch the overview of the new policies from APMA Health Policy Advisor Jeff Lehrman, DPM.