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Medicare Updates on Skin Substitutes: LCDs Withdrawn, Payment Changes Take Effect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 Even though the final LCDs were ultimately withdrawn, the withdrawal is not dispositive of product coverage.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.     


CMS Releases CY 2026 Medicare Physician Fee Schedule Final Rule with Key Payment and Telehealth Updates

CMS issued the CY 2026 Medicare Physician Fee Schedule Final Rule on October 31, 2025, with changes effective January 1, 2026. The Final Rule includes increases to the conversion factor, a new efficiency adjustment, updates to practice expense methodology, permanent telehealth policy changes, revised payment for skin substitutes, expanded rules for Part B drugs and biologicals, enhanced policies for Rural Health Clinics and Federally Qualified Health Centers, and new care management and behavioral health services.

Ohio Department of Medicaid Updates: Key Changes to Physician Reimbursement Rates in Early Parenthood

The Ohio Department of Medicaid has proposed amending Ohio Administrative Code Rule related to covered Medicaid reimbursements for physicians. Beginning on January 1, 2026, they are proposing an increase to rates for prenatal care, childbirth, and infant care and provider visits.

Name, Image, and Likeness Agreements in Healthcare

For example, some healthcare providers have begun to utilize "Name, Image, and Likeness" agreements to promote the brand they have created through their healthcare practice.  We have seen the most healthcare NIL activity with longevity and wellness providers, as well as orthopedics.

Compounding GLP-1 Drugs - Recent Updates

Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.

Top Compliance Risks for Ohio Med-Spas in 2025

The Ohio Board of Pharmacy has increased inspections of med-spas holding Terminal Distributor of Dangerous Drugs (TDDD) licenses, with many facing enforcement actions in 2025. Common issues include purchasing from unlicensed distributors, improper drug storage, inadequate recordkeeping, and insufficient prescriber oversight. Understanding these risks and maintaining compliance can help protect your practice from penalties and license suspension.