What the CY2027 fee schedule means for wound care
A practice-model-by-practice-model read of the CMS CY2027 PFS proposed rule (CMS-1848-P)
On July 16, 2026, CMS published the CY2027 Physician Fee Schedule proposed rule (CMS-1848-P). Open Wound Research read all 716 pages and translated the provisions that touch wound care into plain language. We built a dedicated site to hold the full analysis, organized by how each provision lands on a given practice model.
The headline is that this rule does not treat all wound care the same. Where and how care is delivered largely determines whether CY2027 is a cut or a wash, and who provides the care moves payment further. A few of the load-bearing findings:
- Office and wound-center practices are the most exposed. The proposed modifier -25 policy would pay the most expensive same-day service at 100% and cut the E/M and any other procedure to 50%, directly halving the “E/M plus same-day debridement or skin-substitute application” claims these practices depend on. Combined specialty impacts concentrate here (dermatology -9%, podiatry -4%, plastic surgery -3%), layered on top of a -1.68% conversion-factor decrease.
- Mobile and SNF-based wound care come out comparatively better. CMS proposes to equalize skilled-nursing-facility E/M payment, reversing a CY2026 cut, and the modifier -25 reduction as written spares nursing-facility E/M codes.
- The flagship product change continues: national pricing of non-sheet-form skin substitutes at sheet-form rates, extending the CY2026 overhaul.
The full site walks through E/M and modifier -25, mobile and SNF care, new procedure codes, the “misvalued” services (UltraMIST, autologous PRP, hyperbaric oxygen), skin substitutes, and the specialty-by-specialty payment impact. Every figure is cited to the rule, and analytical commentary is boxed and marked as OWR analysis. The comment period closes September 14, 2026.