How the OPPS and ASC Proposed Rule Would Change Payment Rates for Wound Care

Key Takeaways

• CMS CY 2027 OPPS/ASC Proposed Rule (US): Proposes 2.4% payment increases for services performed in OPPS and ASC settings, effective January 1, 2027 if finalized; 60-day comment period ends August 31, 2026. 
• Skin substitutes (OPPS): Proposes continuing separate reimbursement for skin substitute application and products, maintaining $127.14 per sq. cm. for non-biological skin substitute products licensed outside PHS Act section 351; rate remains not geographically adjusted. 
• Coding updates: Recognizes new HCPCS G0681–G0684 for non-sheet PMA, 510(k), and 361 HCT/P skin substitute applications; no separate payment proposed, with payment packaged into other services.

On July 2, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2027 Hospital Outpatient and Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System Proposed Rule.¹ This document contains proposals from CMS regarding payment policies for services performed in ASC and OPPS settings—eg, a hospital outpatient department wound healing center. 
 
The proposals outlined in this Proposed Rule are subject to a 60-day comment period during which any stakeholder can submit comments about what has been proposed. Some time after this comment period closes and CMS has had an opportunity to consider the submitted comments, the Calendar Year (CY) 2027 Hospital Outpatient and Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System Final Rule will be released. This Final Rule, typically released the first week of November, will detail finalized policies that will take effect January 1, 2027.
 
In the CY 2027 OPPS and ASC Payment System Proposed Rule, CMS proposes to increase payment rates in the OPPS by 2.4% for hospitals that meet their outpatient quality reporting requirements, estimated to result in an increase of approximately $9.5 billion over 2026 payments.¹ CMS also proposes to increase ASC payments by 2.4%, estimated to result in an additional $520 million above 2026 payments. The 2.4% proposed increase is based on a proposed hospital market basket percentage increase of 3.2% and a productivity adjustment of 0.8 percentage points. CMS also proposes to continue to implement a statutory 2% reduction in payments for hospitals that fail to meet the hospital outpatient quality reporting requirements. These payment proposals only apply to OPPS and ASC payments and would not impact payments made directly to practitioners from Medicare payers.
 
The Proposed Rule includes a plan to continue providing separate reimbursement for skin substitute application and skin substitute products in OPPS settings.¹ This includes maintaining a payment rate of $127.14 per square centimeter for skin substitute products applied in OPPS settings that are not “biologicals,” licensed under section 351 of the Public Health Service Act. This OPPS rate of $127.14 per square centimeter will still not be adjusted based on geography for services performed in OPPS settings. In maintaining this payment rate, CMS stated they did not “have sufficient data upon which to propose a revised payment rate.”
 
In the Proposed Rule, CMS recognizes four new G codes, HCPCS G0681–G0684, that represent “application of a premarket approval (PMA), 510(k), 361 human cells, tissues or cellular and tissue-based products (HCT/P) non-sheet form skin substitute.”¹ CMS proposes to add no separate payment associated with these codes, stating that payment is packaged into payment for other services. Stakeholders are invited to submit comments regarding payment of these services provided in OPPS and ASC settings.
 
The Proposed Rule also includes updates to requirements for the Hospital Outpatient Quality Reporting (OQR) Program and the ASC Quality Reporting (ASCQR) Program. 
 
Other aspects the rule include a proposal to allow certain hospital accrediting organizations to assess compliance with Emergency Medical Treatment and Active Labor Act (EMTALA) administrative requirements, a proposal to expand the hospital outpatient department prior authorization program to include certain botulinum toxin injection codes, and proposals that continue to phase out the Inpatient Only Procedures list.¹
 
Comments on these proposals may be submitted to CMS up until August 31, 2026. When submitting comments, authors should reference file code CMS-1850-P. Comments can be submitted electronically at https://www.regulations.gov/docket/CMS-2026-2344. 
 
Comments can also be submitted using traditional mail sent to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1850-P, P.O. Box 8010, Baltimore, MD 21244-8010. Finally, comments may be submitted by express or overnight mail sent to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1850-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.

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. 
 
Reference
1. Department of Health and Human Services Centers for Medicare & Medicaid Services 42 CFR Parts 413, 416, 419, 427, and 488 [CMS-1850-P] RIN 0938-AV83