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March 17, 2026

Revised: Skin Substitute Billing and Coding Article

To improve and simplify the process for skin substitute claims, CGS revised Billing and Coding Article A56696External Website.

Summary of changes effective on April 27, 2026:

  • In an effort to reduce provider burden and improve transparency, we are no longer publishing a list of HCPCS codes. The inclusion of product specific HCPCS codes is not necessary for adjudicating the claim.
  • Adding a list of ICD-10 codes that align with the coverage in the LCD for the use of the products on the lower extremities for diabetic foot ulcers (DFU) and venous leg ulcers (VLU).
  • Removing the C-codes that are no longer active.
  • Providing updated instructions to reduce coding errors and confusion.
  • Updating outdated CMS references and aligning the article with the final rule changes.
  • Clarifying utilization parameters and wastage policy.

Questions & Answers (Q&A)

How do the changes impact products previously included on the list?

We do not limit coverage consideration to products on the list. We have not denied products based on not being included on the list. Therefore, the list is obsolete and not needed to adjudicate claims but has only increased burden given the rapid changes in products.

How are claims for use outside of DFUVLU considered since there are no ICD-10 codes for use?

The LCD (L36690) is specific for lower extremities and coverage is only outlined for DFU/VLU. The use of products outside of these indications is not part of this policy. Claims for non-DFU/VLU use will be handled as any service in which there is not an LCD and may be subject to case-by-case reviews. Use must align with the CMS definition of reasonable and necessary and documentation should be clear regarding the necessity for use.

Upcoming Webinar

CGS will host an educational webinar on March 25, 2026, 12 – 1 pm ET. Please registerExternal Website to attend.

Questions

If you have questions about the changes, please email CMD.INQUIRY@cgsadmin.com.

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