On October 31, 2025, CMS released the final rule for the 2026 Medicare Physician Fee Schedule. CMS will no longer pay skin substitutes under individual biologic codes. Instead, all products will be paid under a single flat “incident-to” supply rate; Approximately $127/cm² per application, regardless of brand or product type.

This replaces the current model where products are reimbursed at their own unique rates. 

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Key Points of the Final Rule to be Aware of for Hospital Based Wound Care Centers:

• The rule takes effect January 1, 2026.
• Flat-rate skin substitute payments will apply in both hospital-based outpatient wound centers and office settings.
• Telehealth and supervision flexibilities from the pandemic will continue permanently.

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What this Means for Hospital Based Wound Centers:

• HOPDs come out ahead. Payment will now be aligned between physician offices and hospital outpatient wound centers, which is expected to shift more wound care volume back into hospital-based settings.
• Office-based / mobile wound care providers will see significant reimbursement cuts. HOPDs likely gain referral volume as clinics reevaluate financial viability for these treatments.

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How to prepare:

• Review your skin substitute inventory and pricing models now.
• Educate your providers and billing staff on the new “incident-to” payment policy.
• Expect referrals to shift back from mobile wound care companies to hospital-based centers.

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Outpatient Prospective Payment System (OPPS) and the Physician Fee Schedule (PFS):

The OPPS and PFS now both align in their policy approach.

• Unpackage the product from procedure payment.
  
• Use FDA regulatory categories for grouping.
  
• Single payment rate in 2026, with planned future differentiation.
  

Stay tuned for a full blog outlining the changes in the OPPS Final Rule.

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Bottom line: 

Reimbursement shifts will bring wound care volume back to hospital-based centers, restoring HOPDs as the central access point for advanced wound care, benefitting both patients and hospitals alike.

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Wound Care Advantage is built for moments like this. We guide hospitals through reimbursement shifts, tighten workflows, and make sure your wound center stays profitable and compliant. You get a steadier operation, stronger outcomes, and a partner focused on keeping these vital programs open for the patients who need them. If you’re looking for a team that knows wound care and shows up when it counts, WCA is here. We’ll help keep your program strong, efficient, and ready for what’s coming. Partner with WCA.

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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.