The American Professional Wound Care Association (APWCA) is urging clinicians and other stakeholders to weigh in during the public comment period for the Centers for Medicare & Medicaid Services’ Calendar Year (CY) 2027 Medicare Physician Fee Schedule.
Public comments are due Sept. 14.
While the APWCA said the fee schedule maintains “relative stability” regarding reimbursement for Cellular, Acellular, and Matrix-like Products (CAMPS) while more claims and utilization information is gathered, the organization noted, “A uniform payment rate does not mean all products have equivalent acquisition costs. … One concern is that 2026 ASP [average sales price] data may not reflect a stable or sustainable commercial market.
“Manufacturers and suppliers may be selling products at heavily discounted wholesale prices to move inventory before expiration, reduce excess stock, or exit the commercial CAMP market altogether. If these temporary or distressed-market prices are later used to establish future universal per-cm reimbursement, the resulting payment rate could be artificially depressed.”
The organization expressed concern about “a downward feedback loop in which reimbursement reductions drive distressed pricing, and those distressed prices are then used to justify further reimbursement reductions. CMS should consider whether 2026 ASP data are sufficiently representative of a normalized market before using them to recalibrate future CAMP payment rates.”
Current sheet-form reimbursement is approximately $127.14 per square centimeter, the APWCA added.
The fee schedule also proposes lower physician reimbursement in facility and non-facility settings, among other changes.
To submit your comments, reference file code CMS-1848-P to access the Physician Fee Schedule.
