Tonia Silva CPC, CPMA, CPPM

Tonia Silva CPC, CPMA, CPPM Consultant in Podiatry & wound care coding & documentation compliance & NextGen Office start up assistance

01/06/2026

As of January 6, 2026, the Physician Fee Schedule is still not available on cms.gov. Whatever that means, I dont know...but for now, when it comes to the vast majority of skin substitutes, those are priced at $127.14 per square cm.
The question has been asked "what do we do with the waste if a product only comes in one size?" Well...you better find a product that has more sizes available! Here is what Medicare is saying:

Q9. Should the JW and JZ modifiers be used when billing for separately payable incident-to supplies?
A9. The JW and JZ modifiers are only used when billing for drugs and biologicals separately payable under Medicare Part B as described in FAQ 8.
The JW and JZ modifiers are not appropriate for billing for incident-to supplies, even if such incident-to supplies are separately payable.

In addition, discarded amounts of incident-to supplies are not payable by Medicare.
..non-BLA skin substitutes are no longer payable under Medicare Part B as a drug or biological as of January 1, 2026, and only the administered portion is payable.

For dates of service starting January 1, 2026:
• If a provider or supplier administers an entire non-BLA skin substitute from the package or container (and no units are discarded), the JZ modifier is not appropriate when billing Medicare.
• If a provider or supplier administers a portion of a non-BLA skin substitute from the package or container and a portion is discarded, the provider or supplier may only bill for the units that are administered. It is not appropriate to bill Medicare for such discarded units under any circumstance (that is, such units may not be billed with the JW modifier and such units may not be included when billing for the administered amount).

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Well, they withdrew the LCD on skin subs...is the fee schedule next?
12/24/2025

Well, they withdrew the LCD on skin subs...is the fee schedule next?

Final Local Coverage Determinations (LCDs) for Certain Skin Substitutes Withdrawn Effective immediately, CMS’ A/B Medicare Administrative Contractors (MACs) are withdrawing the Local Coverage Determinations (LCDs) for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of D...

This is why advise to be very careful with EHRs that code for you.   It's imperative that each provider review what is c...
12/24/2025

This is why advise to be very careful with EHRs that code for you. It's imperative that each provider review what is coded.

A North Carolina software company agreed to pay $529,069 to resolve allegations it violated the False Claims Act by causing providers to bill and MassHealth for medically unnecessary breast cancer screenings. Read more: https://direc.to/fS1e

THIS is why we are in the situation we are in currently in this industry...disgusting...
12/19/2025

THIS is why we are in the situation we are in currently in this industry...disgusting...

In the first prosecution of its kind, the owners of several Arizona wound graft companies were sentenced to significant terms of incarceration for causing over $1.2 billion of false and fraudulent claims to be submitted to Medicare and other health insurance programs for medically unnecessary wound....

CMS adds product coverage categories expanding the number of available CTPs for 2026.
12/16/2025

CMS adds product coverage categories expanding the number of available CTPs for 2026.

Upcoming Update to the Final Local Coverage Determinations (LCDs) for Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers All seven of CMS’ A/B Medicare Administrative Contractors (MACs) will issue updated Final Local Coverage D...

These changes are HUGE and have the potential to greatly affect patient care!
12/06/2025

These changes are HUGE and have the potential to greatly affect patient care!

Beginning January 1, 2026, Medicare Part B will introduce three major policy changes that directly affect how podiatrists provide and bill for skin substitute applications.

To support members through these updates, APMA has developed a concise 20-minute explainer video outlining what’s changing and what practices should prepare for now.

APMA members: Stay informed, stay compliant, and get ahead of the transition.

➡️ Watch the full breakdown here: https://us02web.zoom.us/rec/component-page?eagerLoadZvaPages=&accessLevel=meeting&hasValidToken=false&clusterId=us02&action=play&filePlayId=&componentName=recording-register&meetingId=-mBEOHZ5uIzueFF5S8hJkFK-LKchjfvIIDyw66vb7Ju7JU0PncyYlGBEYrBs7-Sk.tyy24ni_SB3sMMlQ&originRequestUrl=https%3A%2F%2Fus02web.zoom.us%2Frec%2Fshare%2Fd0nKr_LPXVyYQVSH4hKTGvdBq1lMIoDm5te2NKv_VngZKxZW6p9Ef57Y8nJtuAwb.BOFiVQ3KyPk8uttm%3FstartTime%3D1763581440000

Please take the survey.  I have been facilitating the proper documentation for DM shoes for  many years, even won an app...
12/06/2025

Please take the survey. I have been facilitating the proper documentation for DM shoes for many years, even won an appeal at the judicial level!! I can sincerely say that the requirements are burdensome and this directly affects patient care!
https://www.facebook.com/100064730044224/posts/1289559203211736/?mibextid=CDWPTG

APMA is gathering critical information on the documentation challenges podiatrists face when prescribing therapeutic footwear for patients with diabetes under Medicare, and we need your input.

Your input is essential to APMA's advocacy efforts as we work to reduce unnecessary administrative burdens and improve patient access.

Please take a couple of minutes to complete this four-question survey and help strengthen our data on documentation challenges:
https://www.surveymonkey.com/r/XS6GGLB

Wow, errors already?
12/02/2025

Wow, errors already?

CMS Issues “Thanksgiving Leftovers” in the form of Technical Corrections to the CY 2026 Medicare Physician Fee Schedule

Today, November 28, 2025, CMS quietly released a two-page correcting notice via the Federal Register, addressing several “typographical and technical errors” in the CY 2026 Physician Fee Schedule (PFS) final rule. While administrative on the surface, these updates directly impact reimbursement for skin substitute products—a major cost and utilization category in wound care.

Key Changes

• Verbiage in the final rule was corrected to describe skin substitutes as biological products (not “drug or biological products”).
• CMS corrected payment-rate language across several PFS tables.
• The final CY 2026 Medicare payment rate for skin substitutes is $127.14/cm²—not the originally printed $127.28/cm².
• Importantly, this aligns with the rate published in last week’s OPPS Final Rule, ensuring consistency across Part B and hospital outpatient billing.

Looking for more information on the PFS and OPPS, along with more timely updates on CTP regulations and policy? Visit the CTP News Desk for this story and more: https://tinyurl.com/24c638wz

🤯"did not matter which kind of debridement a Vohra physician performed because Vohra allegedly programmed its electronic...
12/02/2025

🤯"did not matter which kind of debridement a Vohra physician performed because Vohra allegedly programmed its electronic health record and billing software to ensure that Medicare was always billed for the higher-reimbursed surgical excisional procedure and to create false medical record documentation to support the scheme"

Vohra Wound Physicians and its owner have agreed to pay $45 million to resolve allegations that they violated the False Claims Act by knowingly causing the submission of claims to for medically unnecessary surgical procedures and wound care services. Read more: https://direc.to/fREt

Great article, thank you Dr Lehrman for making this a bit easier to understand.
11/15/2025

Great article, thank you Dr Lehrman for making this a bit easier to understand.

On October 31, 2025, CMS released its “CY 2026 Medicare Physician Fee Schedule Final Rule.”1 This Rule finalized a new payment model for skin substitute products applied to Medicare Part B beneficiaries during a covered application procedure in a non-facility setting and in the hospital outpatie...

11/14/2025

Stay tuned as more information becomes available on regulatory updates like the following, including this new info on the payment structure in the CMS physician fee schedule for skin substitutes.
https://tinyurl.com/595rsvec

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