CMS Withdraws Proposed LCDs for Skin Substitutes — What Wound Care Providers Need to Know

CMS has officially withdrawn the proposed Local Coverage Determinations (LCDs) for skin substitute products used to treat diabetic foot ulcers and venous leg ulcers. These policies were set to take effect January 1, 2026, but will not move forward at this time. As a result, there is currently no new national or MAC-level LCD governing coverage for these products, and claims will continue to be reviewed under existing Medicare medical necessity standards.

It’s important to note that this withdrawal only affects coverage guidance, not reimbursement. CMS has not paused or delayed the major payment changes finalized under the 2026 Medicare Physician Fee Schedule. Beginning January 1, 2026, most skin substitutes will still be reimbursed under a flat, per–square centimeter supply rate, separate from application services. These payment reforms are moving forward as planned and are independent of the LCD decision.

While the lack of an LCD may temporarily reduce utilization restrictions, it does not signal a shift in CMS’s broader strategy. Providers should continue preparing for stricter documentation expectations, evidence-based product selection, and the financial impact of the new reimbursement model.

If you have questions about how these changes affect your clinic, or want guidance on products that align with both healing outcomes and reimbursement, contact us to learn more.

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