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MASS Coalition Condemns CMS Medicare Rule Threatening Wound Care Access

Key Clinical Summary

  • Recent MASS Coalition statement warns new CMS payment rule will restrict access to life-saving skin substitutes. 
  • Reimbursement rate of $127.28 may render most advanced wound care products unavailable to Medicare patients, they say. 
  • Coalition urges Congress to intervene, citing risks of higher amputations, hospitalizations, and mortality. 

 

 

The Medicare Access to Skin Substitutes Coalition (MASS) Coalition denounced the Centers for Medicare & Medicaid Services’ (CMS) final Physician Fee Schedule rule on skin substitute reimbursement, released November 4, 2025, arguing that it endangers patient access to essential wound treatments and undermines public health outcomes. 

Policy Impact and Potential Patient Risk 

Under the new CMS rule, reimbursement for skin substitutes is capped at $127.28 per application, a rate that the MASS Coalition says fails to reflect the real-world cost of these biologic products.1 According to the coalition, this change will make most FDA-cleared skin substitutes economically unviable, forcing providers to discontinue their use—particularly in Medicare beneficiaries with chronic wounds, such as diabetic foot ulcers and pressure injuries.1 

The coalition referenced National Institutes of Health (NIH) data suggesting that up to 187,286 Americans could lose their lives due to loss of access to these therapies. Clinical evidence shows that skin substitutes reduce emergency department visits, hospital readmissions, and lower-extremity amputations, yielding long-term Medicare savings of approximately $4,000 per patient annually when reimbursement aligns with actual treatment costs.1 

The coalition called on Congress to halt the implementation of the rule and require CMS to develop a National Coverage Determination (NCD) based on current clinical evidence.1 

Implications

If enacted, the MASS Coalition contends that the policy could disproportionately harm diabetic and elderly populations, increasing preventable complications and health care costs. The coalition also warned that forthcoming future effective Local Coverage Determinations (LCDs) could further eliminate access to many advanced wound products.1

Conclusion

​​​​​​The MASS Coalition urged CMS to freeze the pending LCDs and collaborate with clinical experts on an evidence-based coverage framework. Without immediate correction, they feel the rule risks reversing decades of progress in limb preservation and chronic wound care. 

Reference

  1. Mass Coalition to Save Our Wound Care. Mass Coalition Denounces Medicare Rule on Physician Reimbursements as Harmful to Patients, Calls on Congress to Intervene. Published 2025. Accessed November 16, 2025. Available at: https://saveourwoundcare.org/media/mass-coalition-denounces-medicare-rule-on-physician-reimbursements-as-harmful-to-patients-calls-on-congress-to-intervene/ 

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