CMS CY 2027 Physician Fee Schedule Proposed Rule: 5 Wound Care Highlights to Watch
CMS has released an advance public inspection version of the proposed CY 2027 Medicare Physician Fee Schedule (PFS), including several proposals that could affect wound care clinicians, outpatient wound centers, and manufacturers of advanced wound care technologies.
Key Takeaways
- Among the proposed rules is one for national payment for non-sheet skin substitutes, replacing contractor pricing with a standardized methodology.
- There is also a new CPT code for fluorescence wound imaging that would receive national valuation, with CMS also seeking feedback on its relationship to wound debridement services.
- CMS proposes updates to practice expense methodology and identifies several wound care-related services, including low-frequency ultrasound therapy supplies, for payment refinement.
CMS' proposed CY 2027 Physician Fee Schedule contains relatively few sweeping wound care policy changes compared with last year's proposal, but several provisions are relevant to clinicians and industry stakeholders. The proposed rules are still being reviewed by our team and experts but below are some select highlights to keep watch on.
One significant proposal is a change in payment methodology for non-sheet skin substitutes. CMS proposes moving these products from Medicare Administrative Contractor (MAC) pricing to national pricing, using a methodology consistent with sheet-form skin substitutes. For non-sheet products, CMS proposes that payment be based on the wound surface area treated (sq cm) rather than the physical dimensions of the product itself. CMS states that ongoing analysis suggests the resource costs are generally consistent between sheet and non-sheet products.1
CMS also includes a proposal affecting the Medicare Part B Inflation Rebate Program. The agency proposes clarifying that certain future skin substitute products licensed as biologics under section 351 of the Public Health Service Act would not be excluded from the definition of a Part B rebatable drug. CMS notes there are currently no such licensed skin substitute products, but the proposal would establish policy should these products enter the market in the future.1
The proposed rule also introduces a national valuation for new CPT code 976XX, which would describe real-time fluorescence wound imaging used to identify bacterial burden and measure wound size. CMS proposes a work RVU of 0.80 along with associated physician time and practice expense inputs. The agency is also specifically seeking public comment regarding whether the service will typically be billed with wound debridement codes, including CPT 11042 and CPT 97597, and whether some proposed supplies may duplicate resources already included in those services.1
Separately, CMS proposes reducing the practice expense supply price associated with the low-frequency ultrasound wound therapy kit (SA119) as part of its ongoing review of direct practice expense inputs.1
Finally, CMS proposes several broader Medicare payment policy changes that could affect wound care practices, including revisions to practice expense methodology, continued refinement of payment policies, telehealth updates, updates to remote patient monitoring, and broader evaluation and management payment proposals that may influence reimbursement across outpatient wound care settings.
More Information to Follow
Visit the Wound Care Policy News Desk for more details as they emerge, including key analyses and insights from stakeholders in the field and a more complete picture of the proposed rules and what they mean.
Reference
1. Centers for Medicare & Medicaid Services. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program. Proposed rule. CMS-1848-P. Department of Health and Human Services. July 14, 2026. Accessed July 15, 2026. https://www.cms.gov/medicare/payment/fee-schedules/physician/federal-regulation-notices
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