Advocacy Accomplishments
The Alliance's impact in 2025 was extensive.
Amid significant shifts in Medicare payment & coverage and increasing federal scrutiny of wound care, the Alliance advanced members’ priorities and perspectives to shape policies, protect patient access, support clinician practice, and ensure quality wound care.
- Supported separate payment for CTPs that removes access barriers in HOPDs. Building on years of advocacy on past payment proposals, the Alliance submitted detailed recommendations that supported and informed CMS’ new site-neutral, separate payment structure for Cellular & Tissue-based Products for wounds (CTPs or "skin substitutes") included in both the CY 2026 Physician Fee Schedule and the Hospital Outpatient Prospective Payment System. Changes will reduce fraud/misuse, and decrease Medicare spend on this product category. With the unbundling and separate payment of CTPs driven by Alliance advocacy, hospital outpatient departments win since they will now be able to provide these products to patients with larger wounds. CTP payment remains a priority area of advocacy focus, and the Alliance will be collecting insights and impacts from members to elevate to as CMS embarks on setting the differentiated payment rates for CTPs across FDA regulatory categories for CY 2027.
- Supported implementation of clinically flexible, evidence-based CTP LCDs. Throughout 2025, the Alliance reiterated support of the CTP (skin substitute) local coverage determinations finalized in 2024 that our advocacy helped to shape -- policies that after prior release, withdrawal and reissuance now reflect a substantial amount of stakeholder feedback to preserve clinical flexibility, protect evidence-based use of CTPs, and provide a process for evidence submission to expand covered products. The Alliance alerted members to 2025 implementation delays and led programs to educate clinicians about implementation. While the LCDs were ultimately withdrawn in late-December just days prior to their implementation date, the Alliance still believes that LCD implementation is important for appropriate coverage of CTPs that have clinical evidence and to ensure that they are used appropriately.
- Sought improved national payment for blood-derived products. Building on last year’s success securing a national payment rate, the Alliance continued urging CMS to more appropriately capture complexity, clinician time and supply costs in upcoming rate updates. In 2025, the Alliance forwarded recommendations to the proposed CY 2026 rules as well as conducted a clinician survey to quantify actual pre-, intra-, and post-procedure times, establishing realistic clinical work estimates and positioning the Alliance with additional data as we continue to to seek updated rates in the CY 2027 rulemaking cycle.
- Launched advocacy to establish reimbursement for Point-of-Care Imaging (POCI). The Alliance created a new POCI workgroup in 2025 in response to member interest in establishing better reimbursement and coverage pathways. We conducted clinician surveys to capture POCI technologies currently being used, codes billed and collected new evidence to challenge a non-coverage decision by Palmetto.
- Worked to resolve ongoing surgical dressing claims processing problems. Alerted DMEMAC medical directors to persistent denials and coding inconsistencies, submitted real-world examples, and recommended solutions.
- Stopped flawed non-pressure ulcer cost measure from moving forward. The Alliance identified methodology flaws in CMS’ proposed non-pressure ulcer cost measure and escalated concerns about its inability to fairly assess clinician spend and cost allocation. Due to the combination of the Alliance’s feedback and the Alliance clinician workgroup members not supporting the measure the way it was written, CMS’ advisory committee did not advance the measure. At this time, the measure is being rewritten with Alliance clinical member input.
- Paused FDA’s proposed reclassification of antimicrobial dressings. Escalated concerns to the new FDA and OMB leadership, emphasizing patient access risks. Although scheduled to issue in October 2025, FDA has not issued the final rule — a meaningful regulatory pause that reflects the impact of advocacy.
- Responded to new federal priorities on deregulation and tariffs. Identified numerous opportunities to reduce regulatory burdens in wound care in comments to CMS, HHS and OMB on deregulation. Voiced public health risks associated tariffs on medical equipment and devices.
Over 2025, the Alliance collaborated across our members and workgroups to develop and submit 19 comments and letters to regulators and legislators, elevating perspectives and recommendations from the wound care community in policy development. Our progress and successes are a testament to the strength, power, and influence of having a unified - and tenacious - voice for wound care advocacy.
See how we've been driving change and moving wound care forward for the past 20 years:
For information on accomplishments of previous years, see below:
