Updated December 24: The planned January 1, 2026 LCD crack-down on skin substitutes has been pulled back. As per this Fact Sheet: "CMS’ A/B Medicare Administrative Contractors (MACs) are withdrawing the Local Coverage Determinations (LCDs) for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers that were scheduled to become effective on January 1, 2026."

Medicare’s 2026 Outpatient Prospective Payment System (OPPS) rule introduces some of the most significant changes hospital-based wound centers have seen in years. While much of the attention has been on skin substitute reimbursement, the rule also includes several broader updates that will shape how wound care is delivered, paid for, and managed going forward.

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Here’s what’s changing and why it matters:

1. The Biggest Change: Skin Substitute Payment Is being Restructured

Starting January 1, 2026, Medicare will change how it pays hospitals for skin substitute products also known as CTPs (Cellular-Tissue Based Products) or CAMPs (Cellular, Acellular, and Matrix-like Products). 

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What’s changing:

• Medicare will no longer pay different prices for different skin substitute products.
• Instead, Medicare will pay one flat rate per square centimeter (about $127 per cm2) for all skin substitutes.
• Hospitals will still bill for the procedure, but the product itself will now be paid at this standard rate.

Why is this changing?

CMS has had explosive growth in spending on skin substitutes and has concerns about overutilization and waste. This change is intended to standardize payment, reduce financial incentives tied to specific products, and place more focus on clinical appropriateness. 

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What does this mean for you?

• Margins tied to high-cost skin substitutes will shrink.
• Product selection will matter more than ever. We must be more thoughtful about which products we use and how often to use them.
• Documentation and medical necessity will be under increased scrutiny.
• Upcoming LCD updates will further define which wounds qualify and how often products can be used.

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Key Takeaway:

Medicare has said it will be paying closer attention to how skin substitutes are used. There will be more focus on medical necessity, tighter rules, stronger documentation requirements. In simple terms: hospital wound centers will need to clearly show why a skin substitute is needed and how it's helping the patient.

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2. Increased Price Transparency for Hospital Outpatient Services

CMS is now requiring hospitals to publicly report more detailed and accurate outpatient pricing data. 

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Why This Matters for Wound Care:

• Wound care services billed under OPPS (including debridements, skin substitute applications, and HBOT) are a part of this reporting.
• Patients, insurers, and regulators will have more visibility into costs and services will be easier to compare across hospitals.
• Departments with higher costs may get more questions from leadership or payers.

Wound care isn’t being singled out, but it is included.

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3. Expansion of Site-Neutral (“Site-Neutral Lite”) Payment Policies

CMS continues its push toward site-neutral payment, particularly for drug administration services delivered in off-campus hospital outpatient departments.

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What’s changing:

• Certain drug administration services (such as IV infusions or injectable medications) will be reimbursed at lower, clinic-like rates when provided in off-campus locations.
• This change affects the administration service, not the drug itself.

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Why This Matters for Wound Centers:

• Off-campus wound centers that administer IV antibiotics, IV infusions, or similar therapies may see reduced reimbursement.
• On-campus wound centers are not impacted in the same way.
• This reinforces the need to understand how location and service mix affect payment.

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4. Quality Reporting Program Updates (Not Wound Specific, but STILL important)

CMS made refinements to its Outpatient Quality Reporting (OQR) Program, but no wound-specific quality measures were added.

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What to Know:

• The updates apply at the hospital outpatient level, not individual specialities.
• Wound care is not directly targeted.
• However, wound centers may still be affected through broader hospital metrics such as infection control, ED utilization, or ASC-related reporting.

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Key Takeaway:

Quality reporting changes do not single out wound care, but wound programs should remain aligned with system-wide quality expectations.

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5. Updates Affecting Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)

While RHCs and FQHCs are not paid under OPPS, CMS expanded flexibilities related to telehealth, behavioral health, and chronic care management for these clinics.

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Why This Matters for Wound Centers:

• RHCs and FQHCs play a key role in managing conditions like diabetes and vascular disease.
• This can lead to earlier wound identification and better referrals.
• Advanced wound treatments still remain mainly in hospital-based wound centers.

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The Big Picture

The 2026 OPPS rule signals a clear shift:

• Standardized payment instead of product-driven margins
• Greater transparency and oversight
• Tighter alignment across care settings
• Increased emphasis on efficiency, documentation, and outcomes

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What Hospital-Based Wound Centers Should Do Next

Hospital-based wound centers need to act now—and they should not do it alone. The 2026 OPPS changes demand tighter documentation, smarter product use, and constant attention to compliance. This is the time to partner with experts who live in this space. A partner like WCA helps ensure your center is meeting coverage rules, documentation standards, and operational requirements before audits and denials hit. Centers that plan early, with the right support, protect margins, reduce risk, and stay focused on what matters most—healing patients and keeping the program strong.

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What This Means for Health Systems and Hospital Networks

For health systems with multiple wound centers, these changes expose variation. Different products. Different documentation habits. Different financial results. Flat-rate payment and increased oversight make inconsistency expensive. Network leaders will need visibility, standardization, and control across all sites. This is where strategy beats reaction. Wound Care Advantage helps health systems align policies, product use, documentation standards, and performance across every center—without taking control away from the hospital. 

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How Wound Care Advantage Helps You Navigate 2026

This is not new territory for us. We help wound centers adapt when the rules change. Our experts guide product strategy, documentation standards, and operational workflows built for compliance and sustainability. We provide real-time data, authorization review support, and daily coaching for your team. We don’t take your revenue. We strengthen your program. Our job is simple: keep wound centers open, compliant, and effective—so they can keep saving limbs and lives.

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About Wound Care Advantage

WCA helps wound centers run better—clinically and financially. Our platform, Luvo, delivers real-time business intelligence, compliance tools, and daily operational support, all in one place. Built for speed, clarity, and results. We give your team the expertise needed to be successful in wound care—without giving up control. Learn more at www.thewca.com.

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