Medicare payment policy can directly influence how patients receive treatment, which therapies providers can reasonably offer, and where care is delivered. For patients living with chronic wounds or limited mobility, these changes can have consequences beyond billing. At West Coast Wound & Skin Care, we are closely following the proposed 2026 / CY2027 Physician Fee Schedule (PFS) and related Medicare policies because access to appropriate treatment remains central to our mission. Always, we provide the caliber of wound care patients deserve.
The proposed rules continue a significant reimbursement shift that began in 2026, while also introducing additional changes that could affect providers and patients in 2027.
Takeaways from the Proposed CMS Medicare Rules
What patients and providers should know
The Centers for Medicare & Medicaid Services (CMS) issued the CY 2027 PFS proposed rule on July 14, 2026. The proposal would establish Medicare payment policies for services furnished beginning January 1, 2027, although proposed provisions are not final until the rulemaking process is complete. CMS is accepting public comments through September 14, 2026.
Several provisions deserve attention from anyone involved in chronic wound treatment:
- CMS proposes to maintain the $127.14-per-square-centimeter payment rate for many cellular, acellular, and matrix-like products rather than introducing differentiated rates in 2027.
- CMS proposes bringing certain non-sheet products into the same national pricing framework.
- The proposed Physician Fee Schedule includes changes affecting evaluation and wound management services and same-day procedures.
- CMS continues to emphasize payment policies that encourage care in the lowest appropriate setting.
- The proposed changes could place additional financial pressure on independent, office-based, mobile, and other non-facility providers.
- The continued reimbursement pressure makes access and continuity particularly important for patients who cannot easily travel to institutional settings.
The broader direction is consistent with the policy trend already visible in 2026: CMS is seeking greater standardization, more evidence-driven utilization, and closer attention to the cost of delivering services in different settings.
For us, that policy environment reinforces the value of maintaining flexible options for patients. West Coast Wound & Skin Care provides services in patients’ homes and residential care settings, while also offering clinic-based appointments in selected regions.
Our goal is to keep treatment accessible without making a patient’s ability to travel the deciding factor in whether care is available.
Fixed Reimbursement Rates & Skin Substitutes (CAMPs): What Changed?
How the $127.14-per-square-centimeter rate affects treatment
The 2026 Medicare policy changed how many Cellular, Acellular, and Matrix-Like Products (CAMPs), also commonly discussed as CTPs or skin substitutes, are reimbursed when used in applicable settings. Instead of relying on product-specific payment methodologies, CMS established a standardized payment approach that resulted in a rate of approximately $127.14 per square centimeter.
The proposed 2027 rule would keep that flat rate rather than immediately moving to separate rates based on product categories. An analysis published by HMP Global Learning Network notes that CMS says it does not yet have sufficient CY 2026 claims data to responsibly establish differentiated rates, pushing that potential decision toward 2028.
That distinction matters because products can have substantially different acquisition costs. When reimbursement does not account for those differences, providers may have difficulty using certain products while maintaining a financially sustainable practice.
CMS is also proposing to expand the standardized national pricing framework to certain non-sheet products that were previously subject to Medicare Administrative Contractor discretion. The proposal would use wound surface area as the basis for payment rather than continuing separate local approaches for these products.
Site-of-care neutrality & Multiple Procedure Payment Reduction (MPPR)
The reimbursement issue becomes more complicated when the location of treatment is considered. A national clinician survey published in 2026 found significant disruption among non-facility, mobile, home-based, assisted-living, skilled-nursing, rural, and community-based providers following the 2026 payment change.
The concern is partly related to the fact that hospital outpatient departments can receive a separate facility payment in addition to the CAMP reimbursement.
This raises a significant site-of-care neutrality question. If the same clinical service carries different financial realities depending on where it occurs, patients may ultimately be encouraged toward locations that have greater institutional infrastructure, even when treatment at home or in another community setting may be more practical.
The proposed rules also address Multiple Procedure Payment Reduction, including a proposed extension affecting same-day evaluation and management services billed with modifier-25. HMP Global Learning Network reports that CMS is proposing payment at 100% for the highest-valued service and 50% for additional applicable services performed the same day.
For providers whose appointments frequently involve assessment followed by a procedure, this could have meaningful financial consequences if finalized. It is another reason practices must monitor coding, documentation, scheduling, and reimbursement closely.
The Impact on Independent and Mobile Wound Care Providers
Why home-based access remains essential
One of the clearest concerns surrounding the 2026 reimbursement change is its effect on non-facility providers. Vizient reported that mobile providers had been exiting the market following the January 2026 reimbursement changes, describing a broader shift toward hospital-managed outpatient settings.
For patients, however, mobility limitations do not disappear because reimbursement policy changes.
A person recovering from surgery may have difficulty getting into a vehicle. Someone with a pressure injury may spend most of the day in bed or a wheelchair. A patient with a diabetic foot ulcer may have mobility limitations that make repeated travel challenging.
Residents of assisted living, board-and-care, or skilled nursing environments may also benefit from receiving treatment where they already live.
Our mobile care model is designed around that reality. We travel to patients in homes and residential care settings, including assisted living, board-and-care, hospice, and skilled nursing environments.
How West Coast Wound is navigating the reimbursement shift
We recognize that Medicare policy affects the economics of delivering advanced treatment. Rather than allowing reimbursement changes to determine whether patients can access appropriate clinical attention, we continue to evaluate how our services can remain accessible and sustainable.
Our approach includes:
- Maintaining both mobile and clinic-based care options where available.
- Coordinating with patients, caregivers, facilities, and referring providers.
- Creating individualized treatment plans based on each patient’s condition and circumstances.
- Using evidence-based medicine and appropriate clinical technologies.
- Monitoring patients over time rather than treating each appointment as an isolated encounter.
- Supporting care in familiar environments when traveling to a clinic presents a meaningful barrier.
Our wound care providers treats conditions including chronic wounds, pressure injuries, and diabetic foot ulcers, while our broader medical group also provides dermatology services.
This flexibility is especially relevant as reimbursement pressures could encourage consolidation into larger institutional settings. Mobile treatment can help preserve an option for patients who are medically or physically unable to make frequent trips elsewhere.
How Practices Can Ensure Continuity of Patient Care
Documentation, coordination, and patient-centered planning
As payment policies evolve, continuity requires more than knowing the latest reimbursement rate. Providers need reliable clinical documentation, appropriate coding practices, communication with referring providers, and clear treatment plans.
For patients, this means asking practical questions about how their care will continue if reimbursement policies affect the availability of a particular therapy or setting.
For our wound management team, continuity begins with assessing the whole patient rather than focusing only on the visible wound. We provide a coordinated approach that considers factors affecting healing and emphasizes communication with agencies and facilities involved in a patient’s care.
This can be particularly valuable when treatment takes place outside a traditional medical office. A home-based appointment allows our clinicians to evaluate the patient in the environment where daily care occurs and coordinate with caregivers when appropriate.
What Patients Should Watch as Medicare Rules Develop
Proposed does not mean final
The CY 2027 PFS is still a proposed rule. CMS is gathering public comments before issuing its final policies, so specific provisions may change before implementation.
Patients should therefore avoid assuming that every proposed payment provision will become permanent. At the same time, providers cannot afford to ignore the direction of the proposed rule.
The current policy signals continued scrutiny of:
- Skin substitute utilization and reimbursement.
- The economics of different sites of care.
- Documentation and utilization management.
- Same-day services and coding practices.
- The relationship between clinical outcomes and Medicare spending.
- Whether advanced therapies can be delivered efficiently in appropriate settings.
For patients, the practical takeaway is to maintain communication with their medical providers and ask about available treatment options if a particular therapy or care setting becomes difficult to access.
For our organization, monitoring these changes is part of maintaining responsible, patient-centered services. We will continue adapting our operational approach while keeping accessibility and clinical needs at the center of our work.
What the Proposed Rules Could Mean for the Future of Wound Care
Preserving access while the payment landscape changes
The CMS proposals reflect a healthcare system placing increasing emphasis on cost, evidence, standardization, and the setting in which services are delivered. The 2027 proposal does not simply represent another annual payment update; it continues a broader policy shift that could reshape how advanced therapies are delivered and reimbursed.
For West Coast Wound & Skin Care, that makes flexibility especially valuable. We continue to offer mobile services for patients who need treatment where they reside and clinic-based care in our established locations. Our focus remains on providing appropriate medical attention while coordinating with patients, families, caregivers, facilities, and other healthcare professionals.
Mobile care remains vital because some patients cannot simply choose a different site of treatment. For a homebound or medically fragile individual, the ability to receive care without unnecessary travel can directly affect whether treatment is obtained consistently.
As CMS moves toward its final 2027 policies and the industry watches potential changes beyond 2027, we will continue evaluating how reimbursement developments affect access and adapting our services accordingly. Patients deserve care that considers both their clinical needs and the realities of their daily lives, wherever they reside.
