CMS shouldn’t fight fraud by cutting access to care for most vulnerable

November 4, 2025 – The MASS Coalition opposes the Centers for Medicare & Medicaid Services’ final rule on Physician Payments for skin substitutes, released Friday, because it will have disastrous effects on the health of patients with chronic wounds. The decision to set payment reimbursement rates at $127.28 will ultimately make the vast majority of skin substitutes unavailable to patients, especially diabetics, who have benefitted greatly from these treatments.

Preventing fraud, waste, and abuse is important, but such initiatives should be directed at bad actors, not patients who are simply looking for the best treatment for hard-to-heal wounds. While the government may save money in the short-term, the long-term result will be more hospital stays, amputations, and deaths. According to the National Institutes of Health, 187,286 Americans would lose their lives from an inability to obtain skin substitutes, and clinical outcomes show these treatments greatly reduce emergency department visits and hospital readmissions.

Medicare shouldn’t limit treatment options that work. CMS should know that there are better ways to stop bad actors than cutting access to life-saving treatments. When paired with proper Medicare payment policy, skin substitutes will save Medicare $4,000 per patient annually. Congress must intervene to protect patients from bad Medicare policy and save lives.

While Friday’s decision is bad for patient access, CMS’ impending release of its Local Coverage Determinations eliminating coverage for the majority of products will be even more damaging to patients. With more medical evidence showing the positive effects of skin substitutes, CMS should freeze these LCDs again to avoid more negative effects for patients and begin work on a National Coverage Determination based on medical evidence.