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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 Even though the final LCDs were ultimately withdrawn, the withdrawal is not dispositive of product coverage.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.