CMS Skin Substitute Payment Changes: Population Health Risks and Access Challenges in Wound Care

New 2026 CMS reimbursement changes for cellular and tissue-based products (CTPs) are poised to reshape wound care delivery. In this Q&A, Shital Sharma, DPM, MS, MBA, breaks down how cost containment efforts may unintentionally impact population health issues such as access, health equity, and long-term outcomes across vulnerable populations. 

Key Takeaways 

• Access at Risk: CMS payment changes may threaten the financial sustainability of wound care centers, potentially reducing access—especially in vulnerable communities. 
• Outcomes to Watch: Hospitalizations, infections, and amputation rates will be critical indicators of the policy’s real-world population health impact. 
• Advocacy & Research Are Essential: The wound care community must lead on policy engagement, interdisciplinary education, and public health research to protect patient access and outcomes. 

From a population health perspective, how do you see the 2026 skin substitute regulatory changes affecting access to advanced wound care? 

These changes are coming as a shock for many clinicians, especially those practicing in traditional wound care settings. There’s real uncertainty around whether providers will still be able to use the products they rely on—and whether they may be forced to shift toward less effective or unfamiliar options. 

From a population health standpoint, this reflects a classic healthcare economics challenge. CMS is clearly aiming for cost containment, which is necessary in a publicly funded system. But we can’t separate costs from access and quality—this is the “iron triangle” of healthcare. You can’t optimize all three at once. 

One major concern is the financial viability of wound care centers. Historically, reimbursement (based on average sales price (ASP) plus 6%) created incentives that supported operational costs like storage, handling, and infrastructure. The new flat-rate model significantly changes that dynamic. 

If wound care centers (many of which are key revenue generators for hospitals) become financially unsustainable, systems may scale them back or close them altogether. That would have serious downstream effects, especially in underserved or high-risk communities. 

When access points disappear, patients must travel farther for care, which leads to delays. And in wound care, even short delays can mean the difference between a stable wound and a serious infection requiring hospitalization. This disproportionately impacts patients with multiple comorbidities and social barriers to care, ultimately worsening health equity. 

Looking ahead, what population-level outcomes should clinicians and stakeholders be monitoring to assess the impact of these changes? 

We absolutely need to track outcomes; but more importantly, we need to drive the research ourselves. 

Key metrics to watch include hospitalization rates, infection progression, and amputation rates. These are critical indicators of whether reduced access to advanced therapies is translating into worse outcomes. 

But beyond that, this is an opportunity for the wound care community to take ownership of the narrative. We need more research not just in clinical journals, but in public health spaces as well. 

As a profession, we play a central role in limb salvage and longitudinal patient care. Yet that value isn’t always fully recognized across the broader healthcare ecosystem. Expanding our research footprint—and collaborating across specialties—will be essential in demonstrating our impact at the population level. 

Is there anything else the wound care community should understand about this moment? 

Advocacy is critical right now. 

Clinicians need to get involved in policy discussions and support organizations like the American Podiatric Medical Association (APMA) and others that are actively working in this space. We also need to do a better job educating our colleagues across specialties about the role of wound care and limb salvage. 

There’s still a misconception that amputation is the default pathway in some cases, when in reality, coordinated wound care can significantly improve outcomes and extend patients’ lives. 

We also need to embrace modern communication channels—especially social media—to educate patients and combat misinformation. Advocacy isn’t just about policy; it’s about visibility, education, and ensuring that evidence-based care remains accessible. 

Dr. Sharma practices with New York Sports and Joints, is the president of the Temple University School of Podiatric Medicine Alumni Board, and the Chief Innovation Officer for BoardsBlast.