Wound Care Advocacy Wins: Separate, Site Neutral Payments for CTPs/Skin Substitutes Remove Access Barriers in Hospital Outpatient Setting; Combat Waste/Fraud/Abuse that has Led to Unsustainable Medicare Spend in Physicians’ Office Setting.
November 2025 – The Alliance of Wound Care Stakeholders commends CMS on its initiatives in the final CY 2026 Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System (HOPPS) to reform the payment system for cellular and tissue-based products for wounds (CTPs, or “skin substitutes”) in its efforts to combat fraud, waste and abuse of these products and address the excessive spending that has made the current payment methodology unsustainable. Following years of persistent advocacy with CMS policymakers, the Alliance believes the establishment of separate, site neutral payment in 2026 enables clinically appropriate site-of-service decisions – with particular impact in the hospital outpatient setting, where the current bundled payment methodology has challenged access and driven care to other sites of service. The Alliance has repeatedly addressed this issue to the Centers for Medicare and Medicaid Services in our comments which had already gained the endorsement of the Agency’s Advisory Panel on Hospital Outpatient Payment on policy fix recommendations. CMS had not acted on those recommendations until now. In an advocacy “win” for patients and providers alike, HOPDs will now be more able to provide CTPs to patients with larger wounds rather than shifting them to alternate sites of care.
Separate, Site Neutral Payment & “Win” for Access in the Hospital Outpatient Setting...
