CMS 2025 Final Payment Rules: Key Takeaways for Wound Care Providers

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The Centers for Medicare & Medicaid Services (CMS) recently issued final payment policies for 2025, establishing Medicare reimbursement rates over the year ahead that will have broad impact across the US healthcare system as well as specific impacts to wound care.¹
 
Below, the Alliance of Wound Care Stakeholders provides a summary of the most relevant provisions in the 2025 Medicare Physician Fee Schedule, Hospital Outpatient Prospective Payment System (PPS), and Home Health PPS.

2025 Medicare Physician Fee Schedule

The Medicare Physician Fee Schedule sets payment rates for services rendered to Medicare Part B beneficiaries. Provisions impacting wound care in 2025 include:¹
 
Autologous blood-derived products for diabetic wounds. For the first time, CMS established a national payment rate for autologous platelet-rich plasma (PRP), or other blood-derived product for use in treating chronic diabetic wounds (HCPCS code G0465).¹ Previously, each Medicare Administrative Contractor set pricing separately. The result was inconsistent pricing that failed to account for the complexity and costs of these unique products prepared from a patient’s own blood.
 
CMS finalized a national payment rate for G0465, so beginning on January 1, 2025, these products will no longer be contractor-priced.¹ Under the new national pricing, the supply code in the non-facility setting is $770.83 (increased from the $678.57 originally proposed). In the non-facility setting, the national payment is $890.18 (debridement included). In the facility setting, the payment rate (professional fee) will be on par with the rate for cellular and tissue-based product (CTP, or skin substitute) applications.
 
The increase in payment rate from the proposed rule to the Final Rule shows that CMS considered stakeholder input. However, the Alliance and many other stakeholders believe this new national payment rate also fails to reflect the costs associated with the complex preparation and administration of these products—hindering clinicians’ ability to provide these products. Advocacy for more equitable reimbursement will continue.
 
CTPs. While in prior years CMS has proposed significant changes² to CTP payment methodology (which ultimately never finalized or moved forward due to the outpouring of stakeholder comments), for 2025 no changes were made to the existing payment method for CTPs in physician offices.¹ However, the Agency did state intentions to release policy proposals in the future to achieve a consistent payment mechanism for all CTPs. The Alliance remains in ongoing dialogue with CMS on this issue and has been on the record numerous times with payment methodology recommendations that protect provider and patient access to these products.
 
Caregiver training codes. CMS included new codes for caregiver training services—allowed with or without the patient present—to provide support for patients with an ongoing condition or illness.¹ Of particular interest to wound care clinicians, the provisions specifically referenced the training examples of “techniques to prevent decubitus ulcer formation, wound care, and infection control.” A few things to know:

• The new codes include G0541 (initial training), G0542 (additional 15-minute increments), G0543 (group training with multiple caregivers).
• When a product like a surgical dressing is provided by a durable medical equipment (DME) supplier, the supplier is responsible and will get paid for the caregiver training so as not to duplicate what is in the durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) benefit requirements. Additionally, caregiver training will not be billable under the Fee Schedule if it is already being separately billed for patients under a home health plan of care for patients receiving at-home therapy.

Physical therapy supervision and documentation. The 2025 Fee Schedules changes 2 important areas for physical therapy providers: CMS now allows remote therapeutic monitoring services to be furnished by occupational therapy assistants and physical therapy assistants under the general supervision of OTs and PTs in private practice.¹ The Agency also eased PT treatment plan signature requirements.
 
Telehealth services. While most Medicare telehealth waivers and flexibilities introduced during the COVID-19 pandemic are set to expire by the end of 2024 absent congressional action, certain provisions are preserved in the 2025 Fee Schedule, including caregiver training via telehealth.¹ Real-time audio and interactive video telehealth services also remain an option under specific circumstances.

2025 Hospital Outpatient Prospective Payment System (HOPPS) Updates

HOPPS governs hospital outpatient service payments. Key highlights for wound care providers include:³
 
CTP payment methodology. This is status quo for 2025.³ While CMS stated it is still considering alternative payment models for CTPs in the outpatient setting, the Agency did not use the HOPPS to move forward changes for 2025. For the year ahead, CMS is continuing to pay for CTPs using the high and low-cost categories, with annual updates to the geometric mean unit cost (MUC) and per day cost (PDC) thresholds (now $50 per sq cm and $833 respectively) that the Agency uses to categorize CTPs as either high-cost or low-cost for 2025.
 
Over the past several years, the Alliance has urged CMS to ensure appropriate access to care in the hospital outpatient department site of service by update inadequate payment methodologies for CTPs in the HOPPS. Again this year the Alliance recommended that CMS:

• enable outpatient departments to be reimbursed for an adequate amount of CTP products for larger wounds so they don’t need to absorb the cost for treating larger wounds
• equalize payment for the application of CTPs regardless of anatomic location of wound

CMS currently has assigned the application of CTPs applied to wounds 100 sq cm or greater on the feet to a lower paying ambulatory payment classification (APC) group than the same size wounds/ulcers on the legs. As a result, outpatient departments are receiving unequal amount of reimbursement when treating wounds of the same size in different parts of the body, even though they require the same amount of product to be purchased.
 
Both recommendations have been endorsed by CMS’ Advisory Panel on Hospital Outpatient Payment and elevated to the Agency for consideration for four years in a row, yet CMS again did not make these updates for 2025.⁴ The Alliance will continue advocacy in this area.
 
Total contact casting (TCC). In August 2024, the Alliance also gained the endorsement of CMS’ Advisory Panel on Hospital Outpatient Payment on its recommendations that CMS enable payment for total contact casting as a separately payable code when performed on the same date of service as a debridement and/or the application of CTP. This update would allow for these standard of care treatments to be performed on the same date of service, avoiding patient inconvenience. In the final HOPPS rule, CMS acknowledged the Panel’s recommendation but did not implement this suggested change.³ The Agency did state “we will take commenters’ suggestions into consideration for future rulemaking.”³ The Alliance will continue to advocate on this issue.
 
Autologous blood-derived products. CMS finalized payment methodology to make separate payments for these products (HCPCS code G0465) through APCs rather than packaging payment for them into payments for the procedures with which they are administered.³ The payment rate for these increased from $1,739 to $1,829 in 2025.
 
Prior authorization. The review timeframe for standard prior authorization requests for certain covered outpatient department services paid under the OPPS was reduced from 10 business days to 7 calendar days.

2025 Home Health Prospective Payment System (HHPPS) Insights

The Home Health PPS is the payment structure used by Medicare to reimburse home health agencies for services provided to patients. Here’s what is most relevant to wound care:⁵
 
Disposable negative pressure wound therapy (dNPWT). The final 2025 payment rate for dNPWT was set at $276.57, a slight increase over the 2024 rate of $270.09.⁵
 
Lymphedema compression treatment. While lymphedema compression treatment was not addressed in the 2025 Home Health payment update, this remains an important area of advocacy focus. Last year, the 2024 Home Health PPS implemented the Lymphedema Treatment Act and set the coding, coverage and payment for lymphedema compression treatment items mandated by the legislation.⁶ The payment provisions put in place at that time did not provide reimbursement to qualified health professionals for the measuring, fitting, and training services they provide when furnishing patients with these products. Rather the reimbursement was designated to DME suppliers who were to provide payment to the health care professionals. The Alliance is urging CMS to address this issue. Despite tenacious advocacy on this front, CMS did not address this issue in the 2025 HHPPS. This will remain an advocacy area of focus for the Alliance.

The Importance of the Wound Care Voice in Policymaking

For more than 2 decades, the Alliance of Wound Care Stakeholders has been an active advocate for fair reimbursement policies that support high-quality wound care. Progress is often incremental. Advocacy is a long game that requires strategy, tenacity, proactivity, and being consistently on the record as policies evolve. With some of the “wins” for wound care in these 2025 rules are also a number of important issues that demand continued engagement and advocacy. The Alliance will remain tenacious in our collective, collaborative work to promote policies that prioritize patient access, outcomes and equitable coverage and compensation.
 
Marcia Nusgart, RPh, is founder and CEO of the Alliance of Wound Care Stakeholders. Learn more here.

References
 
1. Centers for Medicare and Medicaid Services. Calendar Year (CY) 2025 Medicare Physician Fee Schedule Final Rule. Published Nov. 1, 2024. Accessed Nov. 20, 2024.  
2. Nusgart M. An overview of the 2023 CMS payment policies impacting wound care. Today’s Wound Clinic. 2022; 16(12).
3. Centers for Medicare and Medicaid Services. CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS 1809-FC). Published Nov. 1, 2024. Accessed Nov. 20, 2024. 
4. Alliance of Wound Care Stakeholders. Remove patient access barriers by correcting inadequacies in CTP payments in the 2023 Hospital Outpatient Prospective Payment System Proposed Rule, Alliance of Wound Care Stakeholders urges CMS. Published Sept. 19, 2022. Accessed Nov. 20, 2024.  
5. Centers for Medicare and Medicaid Services. Calendar Year (CY) 2025 Home Health Prospective Payment System Final Rule Fact Sheet (CMS-1803-F). Published Nov. 1, 2024. Accessed Nov. 21, 2024.  
6. Centers for Medicare and Medicaid Services. Calendar Year (CY) 2024 Home Health Prospective Payment System Final Rule (CMS-1780-F). Published Nov. 1, 2024. Accessed Nov. 21, 2024.