2027 Medicare Final Rules: Key Changes for Wound Care

Key Takeaways 

• Skin substitute payment policies differ by setting. CMS will maintain the $127.14/cm² hospital outpatient payment rate for qualifying sheet-form products, while non-sheet products will remain packaged; the physician fee schedule establishes national pricing for non-sheet products. 

• CMS narrowed its same-day E/M payment reduction. The finalized policy applies to separately identifiable office/outpatient E/M services furnished with 0-day global procedures, with the highest-valued service paid at 100% and other applicable services at 80%. 

• Remote monitoring requirements will change. The final rule addresses established-patient eligibility for RTM, initiating visits for RPM and RTM, and a practice-employment requirement for clinical staff beginning in 2029. 

On November 4, 2026, the Centers for Medicare and Medicaid Services (CMS) released the 2027 Hospital Outpatient Prospective Payment/Ambulatory Surgical Center Payment Systems (HOPPS/ASC) Final Rule¹ and the 2027 Medicare Physician Fee Schedule Final Rule.² Below are some key components potentially relevant to those in wound care. 

Skin Substitute Services 

Skin substitute services were addressed in the HOPPS/ASC Final Rule. Skin substitute products with an approved Biologics License Application (BLA) will be considered under transitional drug pass-through payment status in 2027.¹ Also in 2027, CMS will continue to separately pay for skin substitute products in the hospital outpatient setting as incident-to supplies, with the exception of skin substitutes approved as biological products under section 351 of the PHS Act.¹ In the HOPPS/ASC Final Rule, CMS stated they do not believe they have sufficient data upon which to propose a revised payment rate for non-BLA skin substitutes and will maintain the payment rate of $127.14/sq cm for PMA Skin Substitute Products, 510(k) Skin Substitute Products, and 361 HCT/P Skin Substitute Products in the hospital outpatient department setting.¹ Additionally, CMS announced they are not finalizing separate payment for non-sheet skin substitute products in the hospital outpatient department setting, and non-sheet skin substitute products will remain assigned to status indicator “N” in the OPPS setting, meaning they are not separately reimbursed.¹ 

In the 2027 Medicare Physician Fee Schedule Final Rule, CMS finalized its proposal to nationally price the non-sheet form skin substitutes on a per square cm basis, consistent with the payment rates associated with the sheet form skin substitutes.² No changes were made to current sheet form skin substitute reimbursement methodology employed in the private office setting.² 

E/M Submitted With a Procedure 

In the 2027 Medicare Physician Fee Schedule Proposed Rule, CMS proposed to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) service was furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure, where the highest valued service would be paid at 100% and all other services furnished on the same day would be paid at 50%.³ Following a robust response in opposition to this from many stakeholders, CMS modified this proposal. Instead, they finalized a payment reduction when a separately identifiable office/outpatient (O/O) evaluation and management (E/M) service is furnished on the same day as a 0-day global procedure, rather than also including the 10- or 90-day global procedures as proposed.² Additionally, when O/O E/M services are submitted with procedures on the same day, the highest valued service will be paid at 100% and all other services furnished on the same day will be paid at 80%, rather than 50% as proposed.² More stakeholder opposition to this is expected. 

HCPCS G2211 

Changes were made to related to HCPCS G2211 in the 2027 Medicare Physician Fee Schedule Final Rule:²  

HCPCS G2211—Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition.⁴  

Today, in 2026, this code may be submitted as an add-on code when an office or other outpatient evaluation and management (E&M) service is performed, and that E&M is: 

• part of providing all needed health care services for that patient; and/or 

• part of ongoing care related to a patient’s single, serious condition; and/or 

• part of ongoing care related to a patient’s complex condition.  

Starting in 2027, HCPCS code G2211 will be transitioned to a modifier that can be appended to the associated E/M base code, Modifier B1. Appropriate use of this modifier will increase the payment of the associated E/M code by 16%.² 

Remote Monitoring 

For remote monitoring performed in the private office setting, CMS finalized its proposals to only allow coverage of remote therapeutic monitoring (RTM) furnished to established patients, require practitioners reporting remote physiologic monitoring (RPM) or RTM services to furnish a separately reportable initiating visit in association with the onset of RPM or RTM services, and to update how these services are valued under the physician fee schedule.² CMS also finalized a plan to implement a requirement, effective January 1, 2029, that only allows payment for RPM or RTM services when performed by clinical staff that are employed by the practice.² 

Skin Cell Suspension Autograft 

CMS finalized its proposal to adopt the AMA RUC-recommended RVUs and direct practice expense (PE) inputs for skin cell suspension autograft services exactly as they were recommended from the RUC.^1,2  

Real-Time Fluorescence Wound Imaging 

There will be a new Category I CPT code in the 2027 CPT code set to represent “real-time fluorescence wound imaging with clinical darkness to identify presence, location, load of bacteria and measure wound size, per day.” CMS finalized a work RVU of 0.80 for this new code.² The existence of an RVU does not equate to CMS coverage of the service. 

Dr. Lehrman is a Board Certified Podiatrist, Certified Professional Coder, Certified Professional Medical Auditor, and Certified Evaluation and Management Coder. He operates Lehrman Consulting, LLC which provides guidance regarding coding, compliance and documentation.   

References 

1. Centers for Medicare & Medicaid Services. Medicare program: hospital outpatient prospective payment and ambulatory surgical center payment systems; and quality reporting programs; including the Hospital Outpatient Quality Reporting Program and Ambulatory Surgical Center Quality Program; request for information on strengthening the standardization and comparability of hospital price transparency (HPT) data; prior authorization; accrediting organization (AO) deeming for Emergency Medical Treatment and Labor Act (EMTALA); and notices of closure of teaching hospitals and opportunities to apply for available slots. Final rule with comment period. CMS-1850-FC. Accessed November 5, 2026. https://public-inspection.federalregister.gov/2026-22739.pdf

2. Centers for Medicare & Medicaid Services. Medicare and Medicaid programs: calendar year 2027 payment policies under the Physician Fee Schedule and other changes to Part B payment and coverage policies; Medicare Shared Savings Program requirements; etc. Public inspection document 2026-22743. Accessed November 5, 2026. https://public-inspection.federalregister.gov/2026-22743.pdf

3. Centers for Medicare and Medicaid Services. Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule. Available at https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule. Published July 14, 2026.