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Medicare Updates on Skin Substitutes: LCDs Withdrawn, Payment Changes Take Effect

Client Alert

Medicare coverage for skin substitutes has seen significant review over the past year. One notable change in coverage for skin substitutes was set to take effect on January 1, 2026, as indicated by the Centers for Medicare and Medicaid Services (“CMS”) announcement released on December 15, 2025.

The announcement indicated that the Medicare Administrative Contractors (“MACs”) were set to release updated Final LCDs for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. The announcement discussed three categories that the skin substitute products were organized into: (1) Coverage, including products that met the evidence threshold needed for coverage; (2) Non-Covered, including products that lacked submitted evidence showing that the products were “reasonable and necessary” and were without areas of ongoing relevant research; and (3) 12-Month Status Quo Period, indicating that products required further review due to ongoing research. In addition, the announcement listed 18 codes that the MACs identified as covered products, 154 codes subject to MAC discretion, and 158 codes identified as non-covered products.  

On December 24, 2025, CMS announced that the MACs withdrew the Final LCDs. Even though the final LCDs were ultimately withdrawn, the withdrawal is not dispositive of product coverage. Instead, previous coverage rules may still apply. In addition, the Calendar Year 2026 Medicare Physician Fee Schedule Final Rule, which went into effect on January 1, 2026, changed payment for skin substitutes to a single payment rate of app. $127.14.

To learn more about Local Coverage Determinations and Payment Changes for Skin Substitutes, please contact BMD Vice President and Healthcare Member Amanda Waesch at alwaesch@bmdllc.com.     


OAAPN | Year In Review: 2026 Ohio Board of Nursing and Ohio Law Rules

Find out key changes to Ohio law and the Ohio Board of Nursing rules that have directly impacted APRN practice over the past year, including Psychiatric Inpatient Documents, Intimate Examinations, Signature Authority, Duties Related to Fetal Death, Retail IV Therapy Clinics, Release from Permanent Restrictions, Disciplinary Action, Course on Drugs and Prescriptive Authority, Overdose Reversal Drugs, Office Based Opioid Treatment, Withdrawal Management for Substance Use Disorder, Safe Haven Program, and more.

Ohio House Bill 537: Proposed Regulations for Midwives and Birthing Centers

House Bill 537, introduced in the Ohio House of Representatives, proposes a comprehensive regulatory framework for certified nurse-midwives, certified midwives, licensed midwives, and traditional midwives. The legislation would clarify scope of practice, establish licensure standards, and impose new requirements for freestanding birthing centers and home births. Healthcare providers and facilities should be aware of the proposed changes and their potential operational impact.

Proposed Health Information Privacy Reform Act Expands Protections Beyond HIPAA

The Health Information Privacy Reform Act (HIPRA) seeks to extend privacy protections to health data not covered under HIPAA, including data collected by apps and wearables. HIPRA introduces broader definitions of protected health information, strengthens privacy and security requirements, establishes patient notification rights, and sets national de-identification standards. Companies processing health data should monitor developments to ensure compliance.

Understanding the Seven Core Elements of an Effective Healthcare Compliance Program

The Affordable Care Act requires healthcare providers participating in Medicare, Medicaid, and CHIP to maintain an effective compliance program. Guidance from the Department of Health and Human Services and the Office of Inspector General outlines seven core elements that form the foundation of these programs, from written policies and compliance oversight to auditing, training, and corrective action. This alert highlights each element and explains how practices can tailor compliance programs to their size and risk profile while meeting federal expectations.

Preventing a Board Investigation

Healthcare professionals in Ohio are subject to licensing board investigations that can lead to disciplinary action. Staying compliant with regulations, documenting carefully, and operating within your professional scope can help prevent issues. If contacted by a board, working with an attorney is critical to protect your license and rights.