The Alliance submitted comprehensive comments to CMS’ proposed CY 2026 Medicare Physician Fee Schedule (CMS-1832-P) focused on a range of provisions impacting wound care. The Alliance agreed with CMS that the current utilization and reimbursement for CTPs (skin substitutes) in the physician office setting has led to a significant and unsustainable growth in spending and there is a need to “limit some of the current profiteering practices occurring.” The Alliance applauded CMS for addressing this issue that has been plaguing the industry for several years. The current methodology has created perverse incentives that resulted in explosive growth in spending, with little to no correlation to improved outcomes. While the Alliance does not agree that CTPs are “supplies,” we do support CMS’ proposal to pay for CTPs separately as "incident-to-supplies" without bundling or packaging, creating site neutral payment under both the PFS and OPPS. “Separate payment appropriately recognizes these products’ distinct value in improving outcomes for patients, enhances access, and promotes clinically appropriate site-of-service decisions,” the Alliance wrote. Comments requested an increase to the proposed 2026 payment rate and provided inputs on the new payment methodology and proposed creation of reimbursement levels for CTPs based on FDA regulatory categories.

Alliance comments to the Physician Fee Schedule also recommended:

• Efficiency Adjustment withdrawal
• Blood and Blood Derived Products payment adjustment
• Hyperbaric Oxygen Therapy coding methodology
• Point of Care Imaging (POCI) reimbursement under Software as a Service (SaaS) frameworks
• Therapeutic Shoes for Diabetic Patients access improvements

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