I am writing to share my perspective on an urgent issue impacting patients with chronic wounds and the future of regenerative wound care therapies: the establishment of a Medicare fee schedule for cellular, acellular and matrix-like products (CAMPs).
There is broad agreement across the clinical and wound care communities that a standardized, transparent fixed fee schedule is appropriate to simplify the current unpredictable system dominated by ASP (Average Sales Price) pricing.
However, the currently proposed rate of $125.38 per cm² is insufficient and threatens to undermine access, innovation, and the sustainability of responsible wound care practices. It does not reflect the cost of care delivery, product development, or the diversity of wounds that require treatment. We urge Congress and CMS to gather additional further information before finalizing any pricing structure.
This issue is too important for fragmentation or rushed decisions. We urge Congress to:
- Delay implementation of any finalized rate until further data on product cost, clinical outcomes, and access impact are collected.
- Support the collection of robust utilization and outcomes data across wound types and care settings.
- Learn from economic modeling to help determine pricing that is equitable, fiscally responsible, and outcomes driven.
- Protect access to CAMPs for appropriate indications (diabetic, pressure injuries, venous, arterial, dehisced surgical wounds, etc.).
- Continue to underscore inappropriate use and create safeguards against system abuse.
A modern, patient-centered framework must integrate clinical evidence and discourage misuse while expanding access to underserved patients, especially in rural areas, who could benefit.
We also strongly support the bipartisan Skin Substitute Patient Access and Payment Reform Act, introduced by Senator Cassidy, which proposes a sustainable reimbursement framework that balances cost containment with continued patient access. The legislation reflects stakeholder consensus and provides a pragmatic solution to address current inefficiencies and inequities in the reimbursement system for CAMPs.
With Medicare projected to spend over $15 billion on CAMPs in 2025 alone, policy decisions must be grounded in real-world data and fiscal responsibility without compromising access or innovation. Let us work together to ensure that Medicare policies reflect clinical realities, economic sustainability, and equitable access.
I welcome the opportunity to share additional insights or collaborate with your office as this policy evolves.