Part B MACs Propose Noncoverage for Fluorescence Wound Imaging
Proposed local coverage determinations from all 7 Part B Medicare Administrative Contractors would designate real-time fluorescence wound imaging for bacterial presence as a noncovered service. Stakeholders can submit comments through November 14, 2026, before the contractors move toward final coverage decisions.
Key Takeaways
- The policies are proposed, not final. All 7 Part B MACs released identical noncoverage proposals on October 1, 2026.
- The MACs contend that there is insufficient evidence that real-time fluorescence wound imaging independently diagnoses wound infection, accurately determines bacterial burden, or improves patient health outcomes compared with standard assessment and management.
- Stakeholders can participate in the comment process through November 14, 2026. Submissions challenging the proposals should include peer-reviewed evidence addressing the MACs’ stated concerns.
While Medicare is a national program, it is administered on a local level by Medicare Administrative Contractors (MACs). There are 7 Part B MACs in the United States. On October 1, 2026, all 7 Part B MACs released identical proposed local coverage determinations proposing to consider Real-Time Fluorescence Wound Imaging (RTFI) for Bacterial Presence to be a non-covered service.1 These proposed policies list 62 references to support this proposal and state that "available evidence does not demonstrate that RTFI independently diagnoses wound infection, accurately determines bacterial burden, or results in clinically meaningful improvements in patient health outcomes when compared with standard wound assessment and management” and go on to propose that the service is not “reasonable and necessary” and, therefore, not eligible for reimbursement.1
The comment periods are open now for all 7 Part B MAC proposals and these comment periods close on November 14, 2026.1 Final policies can be released any time after the close of the comment period and the MACs have a deadline of 1 year from the release of the proposed policies to release final policies. Any stakeholder can submit comments, including any reader of this article. Section 4009 of the 21st Century Cures Act states these policies should be rooted in evidence-based rationale.2 Therefore, the best ammunition for those who want to oppose these proposals is peer-reviewed literature that supports RTFI’s ability to diagnose infection, determine the burden of bacteria, and contribute to clinically meaningful improvements in patient health outcomes when compared with standard wound assessment and management.
The 7 Part B MACs, their jurisdictions, and the emails where one may submit a comment letter on these proposals for each are listed below:
First Coast Service Options: FL, PR, VI
Medical Affairs
2020 Technology Parkway
Suite 100
Mechanicsburg, PA 17050
ProposedLCDComments@fcso.com
Novitas Solutions, Inc: CO, NM, OK, TX, AR, LA, MS, DE, Wash DC, MD, NJ, PA
Medical Affairs
2020 Technology Parkway
Suite 100
Mechanicsburg, PA 17050
ProposedLCDComments@novitas-solutions.com
Wellpoint Federal: IL, MN, WI, CT, NY, ME, MA, NH, RI, VT
National Government Services Medical Policy Unit
P.O. Box 7108
Indianapolis, IN 46207-7108
NGSDraftLCDComments@anthem.com
CGS Administrators, LLC: KY, OH
Earl Berman, MD
Attn: Medical Review
26 Century Blvd., Ste ST610
Nashville, TN 37214-3685
cmd.inquiry@cgsadmin.com
WPS Ins Corp: IA, KS, MO, NE, IN, MI
Juan Schaening-Perez, MD
1717 West Broadway
PO Box 1787
Madison, WI 53701-1787
policycomments@wpsic.com
Noridian Healthcare Solutions, LLC: AK, ID, OR, WA, AZ, MT, ND, SD, UT, WY, CA, HI, NV
Contractor Medical Director (s) Noridian Healthcare Solutions, LLC
Attention: Draft LCD Comments
4510 13th Ave. S, STE1
Fargo, ND 58103-6646
policydraft@noridian.com
Palmetto GBA: WV, VA, NC, SC, TN, AL, GA
Part B Policy
PO Box 100238 (JM)
or PO Box 100305 (JJ)
AG-275
Columbia, SC 29202
B.Policy@PalmettoGBA.com
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. Proposed local coverage determination: real-time fluorescence wound imaging for bacterial presence (DL40415). Medicare Coverage Database. Accessed October 5, 2026. https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdid=40414
2. Proposed LCD (DL 40415) Real-Time Fluorescence Wound Imaging for Bacterial Presence https://www.cms.gov/medicare-coverage-database/view/lcd.aspx?lcdid=4041421st Century Cures Act, Pub L No. 114-255, §4009, 130 Stat 1033, 1185 (2016). Accessed October 5, 2026. https://www.govinfo.gov/content/pkg/PLAW-114publ255/html/PLAW-114publ255.htm
Editors’ Note: Each of the 7 proposed LCDs are identical, thus the reference listed is one of them as a representative example. Please consult your individual MAC’s LCD for specific confirmation of details applicable to your geographic area.
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