Healing Is Not a Line Item To Be Cut
Traverse City, MI – Rebirth Advanced Healing commends the Centers for Medicare & Medicaid Services (CMS) for taking action to address fraud and abuse in the wound care industry. Protecting patients and preserving integrity in healthcare are goals we all share.
However, the approach outlined in Final Rule 1832, which reclassifies skin substitutes as “supplies,” represents a serious step backward for patient access, clinical outcomes and medical innovation.
Final Rule 1832 sets a flat reimbursement rate of roughly $127 per square centimeter for skin substitutes. That amount is less than the cost of producing, storing, and safely applying many FDA-regulated biologic grafts. On paper, that may look like cost control. In practice, it makes advanced wound healing financially impossible for many providers. Clinics will scale back, mobile programs will close, and patients who once had a path to recovery will be left with bandages and pain.
While we appreciate CMS’s intent to curb fraud, the new rule does so in a way that could limit access to life-restoring care for the very people who need it most — veterans, diabetics, and seniors living with chronic wounds. This is not reform; it is restriction.
Biologic skin grafts are not bandaids. They are tissue-engineered, FDA-regulated therapies derived from placental tissue–solutions that have prevented amputations and restored quality of life for patients others had given up on. Bandages cover wounds, biologics heal them.
At Rebirth Advanced Healing, we’ve seen the impact firsthand. In the third quarter of 2025, 98.8% of our patients experienced measurable wound improvement, compared to a national average of roughly 60%. These results are not coincidence. They are the outcome of advanced biological therapies delivered responsibly and ethically by our expert clinicians.
Most recently, our clinical team in Virginia was able to heal a stubborn 132-square-centimeter venous stasis ulcer on the leg of Winifred Washington, 96, in Chesapeake, Virginia. For 2.5 years, Mrs. Winnie, as she goes by, traveled to a wound clinic for weekly visits to have her wound debrided, without any progress toward healing. Our team needed 10 weeks using advanced biologics to completely close the wound.
“It doesn’t feel real,” Mrs. Winnie said. “It feels like a dream and I’m no longer in pain.”
Mrs. Winnie’s story is one of hundreds our team has helped write. Patients who were losing hope until advanced, ethical wound care changed their lives.
“What happened with Mrs. Washington and our other patients isn’t a miracle,” said Dr. Christopher Mason, owner and CEO of Rebirth Advanced Healing. “It’s what happens when patients finally get access to the right care. Too many people live with chronic wounds for years because the system treats symptoms instead of healing.
“Our team’s mission is to change that.”
We believe CMS should engage with clinical leaders, ethical providers and patient advocates to craft a more balanced solution — one that deters abuse without denying patients access to medically necessary biologic treatments that truly heal.
Healing is not a line item to be cut. It is a human right.

