The Time Has Come to Speak Out on the Proposed Physician Fee Schedule

Comments on the proposed 2026 Physician Fee Schedule are due by 5:00 PM Eastern Time on September 12, 2026. We urge you to submit timely comments to CMS and to specifically address the deficiencies in the proposed skin substitute (CAMPs) reimbursement changes.

Why should you submit comments?

It is critical that you make your own voice heard in Washington. While industry and clinician groups will be submitting their comments, CMS values the insight from practicing clinicians and individual members of the community. Additionally the number of comments submitted on a topic can definitely have an influence on CMS’s perception of the overall community’s position. If you have concerns about the proposed PFS, as we do, please take a few moments to let CMS know. The more people that speak out, the more likely CMS is to listen.

How can you submit comments?

Comments may be submitted one of the following three ways. When commenting, please refer to file code CMS-1832-P.

• Electronically. You may submit electronic comments to http://www.regulations.gov. Follow the “Submit a comment'' instructions.

• By regular mail. You may mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, P.O. Box 8016, Baltimore, MD 21244-8016. Please allow sufficient time for mailed comments to be received before the close of the comment period.

• By express or overnight mail. You may send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.

What should we say in our comments?

You should express any concerns you have with the proposed PFS, including the proposed flat rate reimbursement for skin substitutes limited to $125.38 per square centimeter. We suggest you provide background as to your practice and how these changes could specifically affect your practice and your patients including Medicare beneficiaries.

We also suggest you consider aligning with and citing the consensus proposal developed by Dr. William Tettelbach and many other clinical, industry and reimbursement experts,

and endorsed by the American Professional Wound Care Association (APWCA); the Limb Preservation Foundation (LPF); the Independent Wound Specialist Society (IWSS); the American Board of Wound Healing (ABWH); and the American College of Hyperbaric Medicine (ACHM). Tettelbach et al., Safeguarding access, fiscal responsibility and innovation: a comprehensive reimbursement framework for CAMPs to preserve the Medicare Trust Fund, Journal of Wound Care, https://doi.org/10.12968/jowc.2025.0396. (for hyperlink: https://www.magonlinelibrary.com/doi/full/10.12968/jowc.2025.0396). This paper provides a detailed analysis of the issues with the PFS and proposes well-thought out alternatives. Venture participated in the consensus development process and strongly supports the work of Dr. Tettelbach and this group. Aligning many different voices in the community behind a shared position should greatly strengthen its impact with CMS.

As Dr. Tettelbach’s paper points out, CMS improperly considered only hospital-based product pricing in proposing its $125.38 number CMS should certainly consider product pricing available to offices and mobile providers in setting rates applicable to those providers. The reimbursement amount selected must maintain patient access by providing adequate reimbursement to clinicians to allow them to see Medicare patients, often in rural or remote locations, and to afford to provide skin substitutes to patients who need them. And the reimbursed amount should also be sufficient to allow for continued innovation in the space by supporting the development and launch of new products. Based on these considerations, Venture believes that the high end of Dr. Tettelbach’s proposed reimbursement range (~ $700 per sq cm) is the appropriate place for CMS to land and we hope you will join us in advocating for this outcome. Additonally we believe that an increased clinician application fee, closer to the $700 facility fee proposed for the HOPD, should also be available to mobile and office-based clinicians. An increased application fee would take significant financial pressure off of independent wound care practices and allow appropriate usage of skin substitutes for Medicare beneficiaries.

If you would like more information on the PFS and how to comment, please reach out and we would be happy to discuss.