MACs withdraw final LCDs for certain skin substitutes

CMS recently announced that A/B Medicare Administrative Contractors (MAC) are withdrawing final local coverage determinations (LCD) for skin substitute grafts/cellular and tissue-based products for the treatment of diabetic foot and venous leg ulcers. These LCDs were set to take effect on January 1, 2026.

Before this announcement, CMS indicated that all Part B MACs would issue updated versions of the final LCDs, although it delayed the original effective date to allow for additional review. These LCDs were expected to establish strict coverage criteria and provide additional insights into the agency’s plan to address inaccurate skin substitute payments. The withdrawal does not impact Part B coverage of skin substitute products as it stands, and several Part B MACs (Novitas, CGS, and First Coast) have skin substitute policies outside of these LCDs.

However, the withdrawal follows significant changes to skin substitute reimbursement in the 2026 Medicare Physician Fee Schedule and Outpatient Prospective Payment System final rules. CMS reclassified these items as incident-to supplies with a single national payment rate. Although the agency initially finalized a payment rate of $127.28 per square centimeter, it later issued correction notices for both rules and revised it to $127.14 per square centimeter.

As skin substitute payments remain a focus area for CMS, revenue integrity professionals should continue to monitor for coverage criteria updates.

Editor’s note: Find more NAHRI coverage on skin substitutes here.