Skin substitute payment in 2026: what changed for office-based practices

The short version

• Since January 1, 2026, skin substitutes used in a covered application procedure in the office are paid as incident-to supplies under the Physician Fee Schedule.
• The 2026 national rate is $127.14 per square centimeter, before geographic adjustment. Materials quoting $127.28 are out of date.
• The uniform DFU/VLU skin substitute LCDs set for January 1, 2026 were withdrawn. Older LCDs still apply at Novitas, First Coast and CGS.
• The CY 2027 proposed rule would price non-sheet products at sheet-form rates nationally. It is not final.

Paid as incident-to supplies

In the CY 2026 Physician Fee Schedule final rule (CMS-1832-F), CMS finalized paying for skin substitute products “as incident-to supplies when they are used as part of a covered application procedure paid under the PFS in the non-facility setting or under the OPPS.” The rule took effect January 1, 2026.

CMS groups products by FDA pathway — premarket approval (PMA), 510(k) clearance and 361 HCT/Ps — but uses a single payment rate for 2026. Products licensed as biologics under section 351 of the Public Health Service Act stay on ASP-based payment.

The rate: $127.14 per cm²

The final rule first published $127.28 per square centimeter. A correction notice (CMS-1832-CN2, November 28, 2025) changed it to $127.14 per cm² “prior to the application of the geographic adjustments.” CMS's fact sheet still shows the older figure.

The LCDs

On December 24, 2025, CMS announced that the A/B MACs were withdrawing the skin substitute LCDs for diabetic foot ulcers and venous leg ulcers that had been scheduled to take effect January 1, 2026. When we checked the Medicare Coverage Database on October 6, 2026, no replacement LCD — final or proposed — had been posted.

Older skin substitute LCDs remain in effect in three jurisdictions:

• Novitas — L35041
• First Coast — L36377
• CGS — L36690 (latest revision effective September 3, 2026, an annual review with no changes)

Other MACs' general wound care policies may also address skin substitutes. Check your MAC before you apply.

Application codes

Application procedures are reported with CPT 15271–15278. CMS confirmed for 2026 that these codes continue to describe skin substitute application, and the hospital outpatient C-codes (C5271–C5278) were deleted at the end of 2025.

• 15271–15274: trunk, arms and legs.
• 15275–15278: face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet and multiple digits.
• Within each group, the first pair covers total wound areas up to 100 sq cm (first 25 sq cm, then each additional 25 sq cm); the second pair covers 100 sq cm or more (first 100 sq cm, then each additional 100 sq cm).

CGS's billing article notes that codes are chosen “based upon total surface area of anatomical locations and not by number of ulcers.” Confirm final coding with your billing staff.

What the CY 2027 proposed rule would change

The CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P, July 16, 2026) proposes “to nationally price the non-sheet form skin substitutes consistent with the payment rates associated with the sheet form skin substitutes.” It does not propose separate rates by FDA category: the proposed rate table gives PMA, 510(k) and 361 HCT/P products the same value.

Comments closed September 14, 2026. As of October 6, 2026, no final rule had been published. We'll update this page when it is.

What it means for ordering

Because Medicare pays the practice for the product as an incident-to supply, the practice buys the skin substitute — through our wholesale model on net-30 terms. Documentation should follow your MAC's current policy; our documentation audits can check it.

Sources

Checked on October 6, 2026. Medicare policy changes; confirm current versions before relying on them. This page is general information, not billing, coding or legal advice.