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Medicare Updates on Skin Substitutes: LCDs Withdrawn, Payment Changes Take Effect

Client Alert

Medicare coverage for skin substitutes has seen significant review over the past year. One notable change in coverage for skin substitutes was set to take effect on January 1, 2026, as indicated by the Centers for Medicare and Medicaid Services (“CMS”) announcement released on December 15, 2025.

The announcement indicated that the Medicare Administrative Contractors (“MACs”) were set to release updated Final LCDs for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. The announcement discussed three categories that the skin substitute products were organized into: (1) Coverage, including products that met the evidence threshold needed for coverage; (2) Non-Covered, including products that lacked submitted evidence showing that the products were “reasonable and necessary” and were without areas of ongoing relevant research; and (3) 12-Month Status Quo Period, indicating that products required further review due to ongoing research. In addition, the announcement listed 18 codes that the MACs identified as covered products, 154 codes subject to MAC discretion, and 158 codes identified as non-covered products.  

On December 24, 2025, CMS announced that the MACs withdrew the Final LCDs. Even though the final LCDs were ultimately withdrawn, the withdrawal is not dispositive of product coverage. Instead, previous coverage rules may still apply. In addition, the Calendar Year 2026 Medicare Physician Fee Schedule Final Rule, which went into effect on January 1, 2026, changed payment for skin substitutes to a single payment rate of app. $127.14.

To learn more about Local Coverage Determinations and Payment Changes for Skin Substitutes, please contact BMD Vice President and Healthcare Member Amanda Waesch at alwaesch@bmdllc.com.     


Risks of Using AI-Generated, Implied Celebrity Endorsements in Advertising

Businesses using AI-generated celebrity images, videos, or voice simulations in advertising may face significant legal risks if the content falsely implies an endorsement, affiliation, or sponsorship. This article discusses potential exposure under false advertising, right of publicity, consumer protection, and professional conduct laws, and explains why disclaimers may not be enough to avoid liability.

CMS Requires Providers to Use an Updated Advance Beneficiary Notice (ABN) Form by May 12, 2026

CMS has released an updated Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, that all providers and suppliers must begin using by May 12, 2026. The revised form includes clearer language and formatting updates intended to improve patient understanding and compliance.

CMS and Ohio Ramp Up Fraud Enforcement in Home Health and Hospice

CMS and Ohio have launched sweeping new fraud prevention initiatives targeting home health and hospice providers, signaling a period of heightened scrutiny for enrollment, billing, documentation, and EVV compliance. While aimed at combating fraud, these measures also create significant operational and due process risks for compliant agencies, making proactive compliance programs, auditing, and governance more important than ever.

MYTH BUSTER: Can a New Chiropractor Bill Under An Established Chiropractor’s NPI?

Many chiropractic practices mistakenly believe a newly hired chiropractor can bill under an established chiropractor’s NPI while waiting for credentialing approval. In most cases, this is not permitted. Claims should be submitted under the NPI of the chiropractor who actually rendered the service to avoid compliance risks, including potential False Claims Act exposure. This article outlines key billing rules, common exceptions, and practical compliance tips for chiropractic practices.

RNs and APRNs Take Note: Ohio Board of Nursing Mandates a New CE Reporting Period

Ohio’s Board of Nursing has updated the continuing education reporting period for RNs and APRNs. Beginning March 26, 2026, CE credits must be completed between July 1 and June 30 of odd-numbered years, replacing the previous November to October timeframe.