Beginning January 1, 2026, the Centers for Medicare & Medicaid Services (CMS) will implement significant reforms to the reimbursement and coverage policies for skin substitutes.
Skin substitutes are wound care products typically used in the treatment of chronic wounds such as diabetic foot ulcers or venous leg ulcers.
The changes in the CY 2026 Final Rule mark one of the most substantial transformations in over a decade for wound care providers, manufacturers, and compliance teams.
The reforms are introduced alongside increasing regulatory scrutiny and enforcement activity, signaling that CMS’s expanded use of data analytics will influence industry practices.
Author: Kara Sweet (Foley & Lardner LLP)
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