Recap: Analysis of 6,000+ public comments published on CMS-1832-P shows support for reform, but mounting concern that the new Medicare rule would limit patient access to advanced wound care.
Public comments on a sweeping Medicare proposal reveal broad support for reforming how skin substitutes and advanced wound care treatments are reimbursed. But many warn that the proposed rule goes too far, threatening access for patients who rely on mobile and home-based services.
According to an analysis by Rebirth Advanced Healing of more than 6,000 public comments on CMS Proposal 1832-P, many warned that reclassifying skin substitutes as “supplies” and reducing reimbursements by as much as 80% would effectively cut off access to advanced wound care for a broad range of patients who depend on these treatments.
Dr. Chris Mason, CEO of Rebirth Advanced Healing, said he supports CMS’s effort to bring more oversight and consistency to wound care reimbursement, but that this proposal goes too far.
“By cutting reimbursement rates so drastically, it risks taking away access to advanced treatments for the very patients who need them most, particularly those being cared for at home or in assisted living facilities,” Mason said.
Medicare spending on skin substitutes rose from $256M in 2019 to $10B in 2024, prompting DOJ investigations into fraud and overuse. But responsible wound care providers, like Rebirth Advanced Healing, have warned that the proposed cuts swing too far, punishing ethical clinics and patients alike.
A majority of the comments published on the proposed rule centered around assisted living facilities and home health agencies, with concerns over how supplies would be reimbursed dominating the conversation.
In that, wound care, which made up about 2% of total comments, stood out as a sharp example of what’s at stake. Because patients with chronic wounds are overwhelmingly treated in non-facility settings, commenters warned that reclassifying skin substitutes as “supplies” and slashing reimbursement rates could leave some of the most vulnerable patients without access to life-saving treatments.
Clinicians, industry groups, and even some patients described how lower reimbursement could make it impossible to deliver advanced wound care in homes and assisted living facilities.
“I appreciate CMS’s effort to address dramatic price escalation in skin substitute products and to align payment policy across care settings. Establishing a consistent, predictable basis for reimbursement is a sound policy goal. However, the proposed uniform rate would significantly reduce access for patients treated at home or in assisted living, where chronic wounds are most often managed.” — Tracking Number: mdg-8qwc-1ajf (Nurse Practitioner)
“CMS is right to address misuse and overbilling in this space, but cutting reimbursement by 80 percent goes too far. Patients with diabetic foot ulcers and venous leg ulcers will lose access to care in the very settings where healing actually happens — their homes and assisted living facilities.” — Tracking Number: md6-9p3l-sb48 (Victory Wound Care)
Other comments urged CMS to not reclassify amniotic grafts as supplies, arguing “doing so would disregard their proven clinical value and put providers in an impossible position.”
Last month, Rebirth Advanced Healing published its second quarter wound improvement results, backing up that proven clinical value.
Out of 143 patients across Virginia, South Carolina, and New York, 140 experienced measurable improvement in their wounds, meaning the size of the wound decreased during our treatment window. Additionally, only 1.6% of that patient pool were admitted to a hospital for a wound-related reason.
The public has until Sept. 12 to leave a comment on CMS 1832-P. After that date, CMS will review the comments before finalizing a rule later this year. That final rule , which would take effect January 1, 2026, could reshape how and where millions of Americans receive advanced wound care.
