The Centers for Medicare & Medicaid Services (CMS) recently released the 2025 final payment rules, which include impacts on wound care. These rules significantly affect the U.S. healthcare system. Below is a summary of the most important provisions in the 2025 Medicare Physician Fee Schedule (MPFS), Hospital Outpatient Prospective Payment System (HOPPS), and Home Health Prospective Payment System (HHPPS).
2025 MPFS
The MPFS sets the payment rates for services provided to Medicare Part B beneficiaries. Notable changes for wound care include:
- Autologous Blood-Derived Products for Diabetic Wounds: CMS has set a national payment rate for autologous platelet-rich plasma (PRP) and other blood-derived products to treat chronic diabetic wounds (HCPCS code G0465). Previously, payment rates were set by individual Medicare contractors. Starting January 1, 2025, the national payment rate will be $770.83 in non-facility settings for the product alone, and $890.18 with debridement included. This is a step forward but doesn’t fully cover the complex costs of preparing these products.
- Cellular and Tissue-Based Products (CTPs): The payment methodology for CTPs in physician offices did not change in 2025. CMS has expressed intentions to propose a consistent payment mechanism for all CTPs in the future, and the Alliance continues to advocate for fairer reimbursement models.
- Caregiver Training Codes: New codes for caregiver training were introduced, covering techniques like wound care, infection control, and preventing decubitus ulcers. The new codes (G0541, G0542, G0543) apply when training caregivers, even without the patient present. However, training related to durable medical equipment is covered by the equipment supplier.
- Physical Therapy: Two major updates for physical therapy include the allowance for remote therapeutic monitoring by assistants and changes to treatment plan signature requirements.
- Telehealth Services: Some Medicare telehealth flexibilities from the pandemic will extend into 2025, including real-time audio and interactive video services for certain types of care, such as caregiver training.
2025 HOPPS
HOPPS governs payments for HOPPS. Key updates for wound care include:
- CTP Payment Methodology: No changes for 2025, and CMS continues to use high and low-cost categories for CTPs, with annual updates to cost thresholds. The Alliance advocates for more appropriate reimbursement for larger wounds and equalizing payment for CTPs applied to wounds on different parts of the body.
- Total Contact Casting (TCC): CMS has not yet implemented payment for TCC as a separately payable service when performed with debridement or CTPs, despite recommendations from the Advisory Panel. The Alliance will continue advocating for this update.
- Autologous Blood-Derived Products: Separate payments for these products will be made through Ambulatory Payment Classifications (APCs), with the payment rate increasing to $1,829 in 2025.
- Prior Authorization: The review period for prior authorization requests has been reduced from 10 business days to 7 calendar days.
2025 HHPPS
The HHPPS governs payments for home health services. Noteworthy provisions for wound care include:
- Disposable Negative Pressure Wound Therapy (dNPWT): The 2025 payment rate for dNPWT is $276.57, a slight increase from 2024.
- Lymphedema Compression Treatment: Despite advocacy, CMS did not address reimbursement for health professionals who measure, fit, and train patients for lymphedema compression treatment in the 2025 HHPPS. This remains a focus for future advocacy.
The Importance of Wound Care Advocacy
For over 20 years, the Alliance of Wound Care Stakeholders has advocated for fair reimbursement policies that support quality wound care. While some progress has been made with the 2025 payment rules, several issues remain unresolved and will require ongoing advocacy. The Alliance is committed to continuing its efforts to improve access, outcomes, and equitable coverage for wound care patients.
References
Calendar Year (CY) 2025 Medicare Physician Fee Schedule Final Rule.
An overview of the 2023 CMS payment policies impacting wound care.
Calendar Year (CY) 2025 Home Health Prospective Payment System Final Rule Fact Sheet (CMS-1803-F).
Calendar Year (CY) 2024 Home Health Prospective Payment System Final Rule (CMS-1780-F).
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