The Alliance submitted comprehensive comments to CMS’ proposed CY 2026 Medicare Physician Fee Schedule (CMS-1832-P). Alliance feedback and recommendations focused on a range of provisions impacting wound care, including:

• Efficiency Adjustment: The Alliance does not support the proposed 2.5% efficiency adjustment and recommended that the Agency withdraw this proposal. "The across-the-board proposed adjustment across thousands of codes overlooks the wide variation among services – which is problematic and negatively impacts those performing them," the Alliance wrote.
• Cellular and/or Tissue based Products for Skin Wounds (CTPs): While the Alliance does not agree that CTPs are “supplies,” it does support CMS’ proposal to pay for CTPs separately, without bundling or packaging, creating site neutral payment under both the PFS and the Hospital Outpatient Prospective Payment System. “Separate payment for these products appropriately recognizes these products’ distinct value in improving wound care outcomes for patients, enhances access to care, and promotes clinically appropriate site-of-service decisions,” the Alliance wrote. The Alliance emphasized that the Agency's proposed 2026 “incident-to supplies” payment rate of approximately $125.38 per sq. cm. is too low, and proposed alternatives. Comments addressed many additional details of the new payment methodology as well as CMS' proposed creation of reimbursement categories for CTPs based on FDA regulatory categories versus a single reimbursement rate.
• Blood and Blood Derived Products: The Alliance voiced ongoing support for the national payment rate blood-derived products set last year, but sought updates to enable full payment for application of these products to multiple wounds.
• Hyperbaric Oxygen Therapy: The Alliance recommended that CMS maintain the use of the current coding methodology (codes 99183 and G0277) in 2026 to ensure continuity of care, proper reimbursement and alignment with the clinical realities of hyperbaric medicine.
• Point of Care Imaging (POCI): Alliance noted the value of POCI platforms in wound care and recommended that POCI solutions be considered in any future Software as a Service (SaaS) reimbursement frameworks. As POCI tools are often underutilized because their use is not explicitly reimbursed, CMS should develop specific billing codes (e.g., for image capture, interpretation, and care planning) for approved wound care imaging tools, the Alliance recommended.
• Therapeutic Shoes for Patients with Diabetes: Highlighting easily correctable barriers that delay care, the Alliance recommended that CMS update burdensome requirements in Medicare’s Therapeutic Shoe Program for Patients with Diabetes.

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