The APWCA encourages wound care and hyperbaric physicians, advanced practice providers, nurses, practices, hospital-based programs, medical directors, health systems, and other stakeholders to submit comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed Calendar Year 2027 Medicare Physician Fee Schedule.

Physician Fee Schedule CY 2027 Wound Care Implications v.2.docx

Comments are due September 14, 2026.

APWCA is particularly concerned about the potential impact of the proposed policies on two closely connected issues: patient access to medically necessary wound care and the sustainability of the providers and practices that care for Medicare beneficiaries.

Medicare payment policy does more than determine reimbursement. It can influence where care is available, which services can be sustainably offered, whether practices can maintain an experienced wound care workforce, and whether Medicare beneficiaries can continue receiving timely care in their communities.

The proposed CY 2027 policies include several provisions with potentially significant implications for wound care, including:

• reductions in physician professional reimbursement
• a proposed 50% payment reduction for certain qualifying same-day E/M and procedural services
• restructuring of G2211
• continued evolution of CAMP reimbursement
• changes in practice-expense methodology and facility versus non-facility payment
• site-of-care payment differences
• proposed valuation of the new Category I bacterial fluorescence wound imaging code
• changes affecting Remote Physiologic Monitoring and Remote Therapeutic Monitoring
• additional policies affecting hospital outpatient wound care

APWCA supports responsible Medicare stewardship, appropriate utilization, and strong safeguards against waste, fraud, and abuse. At the same time, payment reforms must preserve access to evidence-based care and provide sustainable reimbursement for qualified clinicians and organizations caring for Medicare beneficiaries.

We therefore encourage providers to tell CMS what these proposals would mean in real-world clinical practice.

Comments are particularly valuable when they describe:

• how the proposed policies would affect your ability to continue caring for Medicare beneficiaries
• whether reimbursement adequately reflects the clinical work, medical decision-making, staffing, supplies, and infrastructure required to provide wound care
• how proposed payment changes could affect staffing, service availability, or practice sustainability
• whether policies could shift care from community-based or non-facility settings to higher-cost institutional settings
• potential effects on rural, homebound, medically complex, and other vulnerable Medicare populations
• specific recommendations that would preserve patient access while maintaining Medicare program integrity

You do not need to submit a lengthy policy analysis. Your experience caring for Medicare beneficiaries matters. A concise comment describing the clinical and operational consequences you anticipate can help CMS understand how these policies may function outside of the regulatory and reimbursement models used to develop them.

Submit Your Comment

CMS is accepting comments on the proposed CY 2027 Physician Fee Schedule, CMS-1848-P, through September 14, 2026.

Submit a comment directly to CMS through Regulations.gov

The official rule states that comments must be received by September 14, 2026, to be assured consideration.

Your Voice Matters

APWCA’s mission is centered on improving access to high-quality wound and hyperbaric care through advocacy and collaboration. Protecting patient access also requires ensuring that the clinicians and programs caring for Medicare beneficiaries can remain available and sustainable.

We encourage every member of the wound care and hyperbaric community to participate.

Please submit your comments before September 14, 2026, and help ensure that CMS hears directly from the professionals caring for Medicare beneficiaries every day.