CMS has issued a March 12, 2026 correction to the CY 2026 Physician Fee Schedule (PFS), updating the CY 2026 PFS Final Rule Addendum B to address misclassified skin substitute HCPCS codes. 

Starting January 1, 2026, CMS implemented several changes for Skin Substitutes in Medicare Part B. For details and background information, refer to blog posts  "Skin Substitutes - What’s New in 2026? Navigating CMS Payment Changes"  and  "2026 CMS Rules for Skin Substitutes: Billing, Payment & Coverage FAQ".

Why are these updates relevant? 

The PFS Addendum B lists whether CPT/HCPCS codes are payable, how they are reimbursed, and what RVUs and global periods apply. CMS identified that several skin substitute codes were misclassified or missing in Addendum B, which could have led to incorrect billing assumptions, underpayments or denials, and increased audit risk.

• Under CMS definitions (according to Addendum A):
• Status “A” = separately payable, with RVUs
• Status “C” = contractor-priced (no national RVUs)
• Status “E” = excluded (non-payable under PFS) 

Which Skin Substitute HCPCS Codes Were Corrected in the March 12, 2026 CMS PFS Update?

1. Codes corrected to active, separately payable status (Status “A”)

 Codes A2025, A2029, A2031, A2032, A2034, A2036, A2038, A2039, A4100 and Q4224 (Table 1) were previously listed with incorrect payment status and are now updated to:

• Procedure Status: A (Active)
• Non-Facility PE RVU: 3.81
• Total Non-Facility RVU: 3.81

Implication:

These codes are now recognized as separately payable under the PFS for both facility and non-facility care settings, and will be actively priced with an RVU for codes with this status (Procedure Status A)

Table 1. PFS Addendum B HCPCS codes corrected to active, separately payable status (Status “A”)

2. Codes removed from Addendum B

Codes Q4106 and Q4226 were removed from Addendum B. Billing teams should verify their current reimbursement pathway before use.

• Q4106 Dermagraft
• Q4226 Myown harv prep proc sq cm

3. Codes corrected from non-payable to payable classification

Codes Q4398–Q4420 and Q4431, Q4432, Q4433 (Table 2) were previously assigned Status “E” (excluded/non-payable) in error and were previously omitted from Addendum B:

CMS has corrected these to be included under the PFS: 

• Q4398–Q4420: active pricing (Procedure Status A)
• Q4431–Q4433: Status “C” (Procedure Status C: contractor-priced)

Implication:

Application of these products are no longer considered excluded from the PFS and may now be reimbursed:

• Either through national RVUs (if applicable)
• Or MAC-determined pricing (for contractor-priced codes)

Table 2. Addendum B HCPCS codes corrected from non-payable to payable classification

4. Global period corrections

Codes Q4431, Q4432, Q4433 (see descriptions in Table 2) had their global period updated to ZZZ. This means that these codes are always included in the global period of a related service and are not separately paid when billed alone. 

What does this update mean for wound care programs?

If programs generated claims involving the affected codes in 2026, these changes may have a direct impact on the revenue cycle.

• Claims involving the affected codes - particularly those submitted in early 2026 - should be reviewed for accuracy and may require correction or resubmission.
• Previously denied or underpaid claims related to the affected codes may now be eligible for appeal.
• In parallel, organizations should update their chargemaster and EHR systems to reflect the corrected coding, pricing, and status indicators. Ensure systems reflect:
• Correct Procedure Status (A vs C vs removed)
• Updated RVUs
• Correct global period indicators

Key takeaways

• Even after the PFS Final Rule is published, PFS data is not static.
• Small classification changes (particularly shifts between Status A, C, and E) can materially affect:
• Payment eligibility
• Billing workflows
• Audit exposure
• For skin substitutes, staying current with CMS corrections is essential to ensure accurate reimbursement and compliance.

What actions can wound care programs take after the CMS March 2026 PFS update?

• Review the updated PFS Addendum B (March 2026) once published. Of note, as of March 19, 2026, the file has not yet been updated on the CMS website despite the Federal Register correction notice.
• Audit claims involving affected codes
• Update internal coding and billing references
• Confirm MAC-specific pricing for contractor-priced codes
• If applicable, educate clinicians and billing teams on these changes

Resources

WoundReference

• Skin Substitutes - What’s New in 2026? Navigating CMS Payment Changes
• 2026 CMS Rules for Skin Substitutes: Billing, Payment & Coverage FAQ
  
• Cellular and/or Tissue Based Products
• Medicare Coverage Determinations for Wound Care
• Understanding the WISeR Model: What Wound Care Providers Need to Know
  

CMS

• CY 2026 PFS Final Rule, Correction (March 12, 2026)
• PFS Federal Regulation Notices