A Win for Access - Not the End of Reform: The CAMPs LCD Withdrawal and the Work Ahead

On December 24, 2025, CMS announced that its A/B Medicare Administrative Contractors (MACs) withdrew the future-effective Local Coverage Determinations (LCDs) for skin substitutes, commonly framed as Cellular, Acellular, and Matrix-like Products (CAMPs), for the treatment of diabetic foot ulcers (DFUs) and venous leg ulcers (VLUs) that had been scheduled to take effect January 1, 2026. This withdrawal was a meaningful moment for patient access because it prevented an abrupt shift to restrictive coverage constructs that many clinicians believed were not feasible at the point of care and did not reflect the realities of Medicare beneficiaries with complex, hard-to-heal wounds.

The Wound & Hyperbaric Association (WHA) was instrumental in driving this outcome through a coordinated, evidence-driven advocacy effort conducted throughout 2025 in collaboration with American Professional Wound Care Association (APWCA) members and aligned stakeholders. That effort combined Capitol Hill engagement, grassroots mobilization through petitions and outreach to senators and representatives, coalition “calls to action,” and a series of peer-reviewed Medicare real-world evidence (RWE) and consensus publications that directly addressed the future-effective LCD constructs and proposed workable alternatives. The WHA’s position is grounded in the timing and policy relevance of the evidence produced and the structured delivery of those findings into the policy process.

The future-effective CAMPs LCDs became a national concern because they risked creating “access cliffs,” where patients making progress could be forced to stop therapy due to administrative limits rather than clinical judgment. In real Medicare beneficiary care pathways, wound healing is often non-linear and commonly interrupted by infection, hospitalization, comorbidity destabilization, revascularization, and transitions across sites of care. The WHA and aligned stakeholder partners emphasized that rigid episode constructs and fixed application limits do not reliably account for these realities and can increase the likelihood of treatment failure, downstream complications, and cost-shifting to higher-acuity care when wounds worsen.

A defining feature of WHA’s 2025 campaign was the publication of multiple peer-reviewed works supported through WHA / APWCA collaboration. “The hidden costs of limiting access” (Journal of Wound Care, 2025) evaluated the clinical and economic risks of the future-effective LCD framework, warning that rigid limitations could predictably increase treatment failures and downstream harms. “Safeguarding access, fiscal responsibility and innovation” (JWC; PubMed-indexed, 2025) provided a comprehensive reform framework intended to preserve access while supporting Medicare Trust Fund stewardship, emphasizing outcomes-driven policy, targeted oversight, and workable payment alternatives rather than blunt restrictions. “Rethinking regulatory tiers” (JWC, 2025) further supported outcomes-based policymaking by showing that Medicare real-world outcomes are not reliably predicted by FDA regulatory classification, undermining simplistic tiering assumptions. Additional consensus and policy-oriented publications, which included “Regulatory and reimbursement reform for cellular, acellular, and matrix-like products (CAMPs)” (IJTR, 2025) helped align multidisciplinary stakeholders and translate evidence into actionable recommendations.

The WHA’s combined results of credible Medicare real-world evidence (RWE), practical reform proposals, multidisciplinary alignment, and sustained advocacy engagement helped shape the policy dialogue that culminated in withdrawal of the future-effective LCDs. Looking forward, WHA supports a national, evidence-based rebuild that preserves access while strengthening integrity via continued publication of objective Medicare outcomes, development of clinically feasible national coverage pathways, and sustainable payment models that align incentives with patient-centered results.

Your patient advocacy voice is still need. Support the “Skin Substitute Access and Payment Reform Act” at https://www.whacares.org/advocacy