Update on AATB Advocacy Efforts Related to Skin Substitute Payment Policy

Skin substitute reimbursement has been a challenging issue for our industry, and it has remained one of AATB’s top advocacy priorities. As many of you know, AATB has engaged for years with the Centers for Medicare and Medicaid Services (CMS) on skin substitute coverage and payment policy, including by responding to the annual Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) rules, as well as the Local Coverage Determinations for certain skin substitutes, which were eventually withdrawn last December.

AATB’s recent efforts have included:

• September 10, 2025 – Submitted a letter to CMS Administrator Mehmet Oz, MD, regarding payment for skin substitutes under the CY 2026 Medicare PFS proposed rule.  
• September 12, 2025 – Submitted a letter to CMS Administrator Mehmet Oz, MD, regarding payment for skin substitutes under the CY 2026 Hospital OPPS proposed rule.
• December 4, 2025 – Submitted a follow-up letter to CMS Administrator Mehmet Oz, MD, regarding concerns with the CY 2026 Medicare PFS final rule.
• February 26, 2026 – Hosted a Capitol Hill fly-in where more than 40 AATB members met with over 60 Congressional offices to urge Congress to support language encouraging CMS to reverse the decision to pay for skin substitutes under the Medicare PFS and to work with stakeholders to develop a more sustainable approach to payment for skin substitutes in both the physician office and hospital outpatient setting.
• March 4, 2026 – Issued a member call to action supporting Congressional report language encouraging CMS to reconsider its payment approach for skin substitutes. 
• March 16, 2026 – Distributed a follow-up reminder on the call to action encouraging continued member engagement on the issue.

Throughout these efforts, AATB has consistently emphasized several key points regarding CMS’s current approach to skin substitute payment policy:

• Skin substitutes are essential medical products that play an important role in the treatment of wounds.
• The 2026 payment rate is insufficient to maintain patient access to the current range of skin substitute products, including innovative enhancements that would help physicians choose the most appropriate products for individual patient treatment. 
• Annual recalculation of rates using the most recently available calendar quarter average sales price data is likely to create ongoing downward pricing pressure that could further reduce product availability and patient access in future years. CMS should instead adopt an inflationary update.
• Geographic adjustments to payment rates under the Medicare PFS may create disparities in access, particularly for patients in lower-income communities that may already face greater barriers to care. 

In our meetings with Congressional offices earlier this year, AATB members urged lawmakers to support language encouraging CMS to reverse the decision to pay for skin substitutes under the Medicare PFS and to work with stakeholders on a more sustainable reimbursement framework for both physician office and hospital outpatient settings.

AATB continues to monitor Congressional appropriations activity. The House Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies is expected to mark up its funding bill on June 5, 2026, with consideration by the full House Appropriations Committee anticipated shortly thereafter. Depending on the outcome of those discussions, AATB will evaluate additional advocacy opportunities and continue working to secure an increased payment rate for skin substitutes in the CY 2027 PFS and OPPS final rules.

Thank you again to everyone who has contributed time, expertise, and advocacy to this effort. If you are interested in supporting AATB’s work on skin substitutes, we encourage you to submit a request to join the Regulatory Affairs Council through your Portal Account. Member engagement continues to make a meaningful difference as we work to protect patient access and support a sustainable environment for these important products.