About This Analysis & How to Comment
About Open Wound Research
Open Wound Research (OWR) is an independent wound-care research organization. This site is our reading of the CMS CY2027 Physician Fee Schedule proposed rule (CMS-1848-P) through a wound-care lens. It summarizes the provisions most relevant to clinicians, practice managers, and manufacturers, and may serve as background for those preparing public comments during the comment period.
We are not affiliated with, funded by, or endorsed by CMS.
Methodology & sourcing
- Primary source. Every factual claim traces to the official rule as published in the Federal Register (document 2026-14327, 91 FR 43842). We converted the government’s structured XML of the full rule to text and cite provisions by their rule section (e.g., §II.D(58)) and, where useful, the Federal Register page.
- What we added. Plain-language summaries, the practice-model framing (direct wound care, mobile wound care, wound care center, SNF-based), and analytical commentary. Commentary is clearly boxed and labeled “OWR Analysis”.
- What we did not do. We did not reproduce the rule’s fee-schedule data tables (many are published as images); exact rates appear in the official rule and CMS’s posted data files.
This site is educational analysis of a proposed rule that may change before it is finalized. Nothing here is legal, reimbursement, billing, or coding advice. The official rule and the relevant Medicare Administrative Contractor are the authoritative sources for codes, RVUs, and payment amounts in business or billing decisions.
How to comment
The public comment period for CMS-1848-P is open through September 14, 2026, and CMS reviews timely comments before issuing a final rule. Providers, manufacturers, and other stakeholders who wish to submit input can do so via any one of these routes (CMS instructs commenters to use only one method):
- Electronically: the docket CMS-2026-2377 on Regulations.gov, which provides “Submit a comment” instructions.
- Regular mail: CMS, HHS, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016.
- Express/overnight mail: CMS, HHS, Attention: CMS-1848-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
CMS instructs that all submissions reference file code CMS-1848-P.
What CMS tends to find useful in a comment
For those who choose to submit, agencies generally give more weight to comments that:
- identify the commenter and their stake (clinician, practice, manufacturer, patients served);
- are specific, citing the provision, describing the concrete operational or patient impact, and quantifying it where possible;
- offer data or an alternative approach rather than a position alone.
Comments become part of the public record and are posted publicly, including any personal information they contain.
The full rule
For reference, the complete rule is available from the government: