The Centers for Medicare & Medicaid Services (CMS) has released the  2026 Medicare Proposed Physician Fee Schedule. Several provisions in the rule could have a major impact on care provided in long term care communities. CMS reviews and responds to every public comment, so your input is critical. Submitting a comment should take less than 5 minutes, and every submission helps amplify our collective voice.

Why This Matters – Key Proposed Policies

The proposed changes directly affect how we care for medically complex and frail patients in long-term care settings. Two provisions are particularly important:

• G2211 in SNF and ALF Care – CMS proposes allowing the complexity add-on code G2211 to be billed with E/M services in SNFs (CPT codes 99304–99310) and in ALFs (CPT codes 99340–99350). This would finally recognize the additional time and coordination required for longitudinal care in these settings. Payments for most SNF and ALF visits would increase by roughly 10%.
• Skin Substitutes Payment Reform – CMS proposes paying for non-BLA skin substitutes as “incident to” supplies and setting a $125 per square centimeter payment rate. This change would significantly curb the widespread waste, fraud, and abuse in wound care that is leading to direct harm for our patients. The skin substitute problem was profiled in the New York Times earlier this year.

Please Submit Comments

Your voice matters. Here’s how to submit a quick comment to CMS:

1. Visit the Proposed Rule Federal Register page.
2. Click the green “Submit a Comment” button.
3. Copy and paste the following text into the comment box (add your own perspective if you wish):

As a provider caring for Medicare beneficiaries in skilled nursing facilities (SNFs) and assisted living facilities (ALFs), I strongly support two provisions in the CY 2026 Medicare Physician Fee Schedule.

• CMS should finalize the proposal to allow G2211 to be billed with E/M services in SNFs (CPT 99304–99310) and ALFs (CPT 99340–99350). This recognizes the added time and coordination required for high-need patients and will strengthen comprehensive primary care.
• CMS should finalize the proposal to reclassify non-BLA skin substitutes as “incident to” supplies with a single payment rate. This reform will reduce financial incentives for overuse, promote evidence-based use, and ensure wound care is integrated into broader treatment plans.

Together, these policies support high-value care and protect vulnerable beneficiaries.

1. Identify whether you are submitting the comment on behalf of yourself, your organization, or anonymously.
2. Click the relevant box and then “Submit Comment.”

Moving Forward

Organizations will submit detailed comments on behalf of their members, but real-world voices from practicing long-term care clinicians are the most powerful. Together, we can ensure CMS finalizes policies that support the patients we serve every day.

Thank you for your advocacy and for the essential work you do for residents of long-term care communities.

Choosing Wisely | PALTmed