“Misvalued” Wound Services: UltraMIST, PRP & HBOT

What CMS proposed. Under the annual “potentially misvalued services” process, CMS took up three nominations that touch wound care. For CPT 97610 (low-frequency, non-contact ultrasound wound therapy, the UltraMIST service), CMS agrees the code is potentially “misvalued” and proposes to cut the SA119 supply kit price from $320.18 to $100, while seeking comment on whether physician time (currently nearly 26 minutes total) is overstated relative to the manufacturer’s asserted 6-minute average. For HCPCS G0465 (autologous platelet-rich plasma for chronic diabetic wounds/ulcers), CMS declines a nominator’s request to raise the work RVU from 1.78 to 5.50 and to exempt the code from multiple-procedure payment adjustments, and is not proposing the code as potentially “misvalued”. For HCPCS G0277 (hyperbaric oxygen under pressure, per 30-minute interval), CMS rejects a request from the AMA/Specialty Society Relative Value Scale (RVS) Update Committee (the RUC) to delete the G-code and proposes to maintain it.

Sources: CY2027 PFS proposed rule (CMS-1848-P), §II.D “Potentially Misvalued Services,” items (7), (12), (13). See the full rule.

Ultrasonic wound therapy: 97610 (UltraMIST)

This is the most consequential of the three items. The nominator argued that CPT 97610 is “misvalued” because of an inflated supply cost that creates a site-of-service disparity: at a CY2026 non-facility PE RVU of 11.51, the office-based payment is $384, versus an OPPS (hospital outpatient) rate of $205, a $179 gap.1 The nominator traced the disparity primarily to the $320 SA119 direct PE input (“kit, low frequency ultrasound wound therapy (MIST)”), and pointed to the UltraMIST manufacturer’s own December 2025 investor presentation, which lists consumable costs at roughly $100 per procedure (MSRP for the single-use applicator). Using manufacturer revenue disclosures and Medicare claims data, the nominator further estimated an implied average sales price of about $86 per disposable kit.2

CMS agrees with the nominator. It proposes CPT 97610 as potentially “misvalued” and proposes to change the SA119 supply price from $320.18 to $100 in the direct PE database, inviting interested parties to submit paid invoices for the kit.3

NoteWho nominated 97610?

The rule never names the submitter, calling it only “an interested party” and thereafter “the nominator.” The document behind the nomination in CMS’s potentially misvalued codes (PMVC) file is a June 2026 memo from The RAND Corporation, the research contractor CMS asked to identify potentially “misvalued” services. The overvaluation case therefore originates with CMS’s own contractor.4

CMS also flags physician time. The same investor presentation asserts the procedure takes about 3 to 20 minutes, averaging 6 minutes, while the current valuation assumes nearly 26 minutes of total physician time (work RVU 0.39), including an intraservice time of nearly 15 minutes.5 Because the current intraservice time is more than double the manufacturer’s asserted average, CMS is seeking comment on whether the typical physician time is closer to 6 minutes or to the current 15-minute intraservice assumption.6 A time cut on top of the supply cut would reduce the work side of the payment as well. For how 97610 relates to the broader 976XX active wound management family, see wound procedures.

Autologous PRP for diabetic wounds: G0465

A nominator asked CMS to review G0465, autologous platelet-rich plasma (or other blood-derived product) for diabetic chronic wounds/ulcers, using an FDA-cleared device, inclusive of phlebotomy, centrifugation, administration, and dressings, as potentially “misvalued”. The request had three parts: raise the work RVU from 1.78 to 5.50, based on an independent third-party survey (Fall 2025) of physicians and qualified health professionals experienced in treating chronic non-healing diabetic wounds; state that multiple-procedure payment reduction (MPPR) adjustments do not apply to G0465; and revisit the crosswalk to CPT 15275 (application of skin substitute graft, first 25 sq cm), which CMS finalized in the CY2025 PFS final rule and which the nominator considers inappropriate.7

NoteWho nominated G0465?

The rule refers only to “the nominator.” The nomination on file in CMS’s potentially misvalued codes (PMVC) file is a February 6, 2026 letter from the Alliance of Wound Care Stakeholders, a nonprofit wound-care trade association representing physician specialty societies, provider groups, clinics, and product companies. In contrast to the 97610 nomination, this request asks CMS to raise the code’s value (work RVU 1.78 to 5.50), so it originates with an industry group rather than a CMS contractor.8

CMS declined on all three fronts. It notes the survey had only 34 respondents and questions whether that is a representative sample of practitioners furnishing the service; it continues to believe MPPR properly applies to multiple units billed for the same beneficiary on the same day, given overlapping resource costs; and, absent additional supporting information, it is not proposing G0465 as potentially “misvalued”.9 This is a rejection of the nomination, not a proposal to adopt the 5.50 value; CMS’s stated basis is the absence of additional supporting information beyond the 34-respondent survey.

Hyperbaric oxygen: G0277

The G0277 discussion is about coding structure, not payment levels. The RUC requested that CMS delete HCPCS G0277 (hyperbaric oxygen under pressure, full body chamber, per 30-minute interval) and revise CPT 99183 (physician attendance and supervision of HBOT, per session) to be time-based, arguing that a separate G-code creates unnecessary coding complexity without clinical or administrative value.10

NoteWhat is the RUC?

The RUC is the AMA/Specialty Society Relative Value Scale (RVS) Update Committee, a private committee convened by the American Medical Association whose members are appointed largely by national medical specialty societies. Each year it recommends physician work and practice-expense values to CMS for the fee schedule. CMS is not bound by those recommendations.11

CMS disagrees. It recounts that it created G0277 in 2015 to describe the direct PE inputs associated with 99183 and to maintain consistency with OPPS coding (the former C1300 treatment code).12 G0277 was identified as a high-volume growth code with Medicare utilization of 10,000 or more, which CMS says reflects broad adoption across multiple care settings; deleting a high-volume code without an equivalent could disrupt billing, create reporting gaps, and impose administrative burden.13 Because G0277 is used in multiple Medicare payment systems to report the time a patient spends in the chamber, CMS proposes to maintain the code.14 The proposed rule does not discuss changes to G0277’s values in this section; the item is narrower than the nomination framing suggests and does not contain any proposed HBOT payment change.

Why it matters for wound care

The 97610 proposal is a direct, quantified cut to office-based ultrasonic wound therapy: the SA119 supply, the single largest input behind the $384 non-facility rate, would drop by roughly $220 per treatment, and CMS has opened the door to also cutting the assumed physician time by more than half. For practices that have built UltraMIST into their chronic-wound protocols, the total effect depends on both components: the supply cut alone and the supply cut combined with a time reduction imply different payment levels. The G0465 decision means PRP for diabetic ulcers stays at a work RVU of 1.78, crosswalked to 15275, with MPPR applying when multiple units are billed, a status quo that the nominator considers undervalued; CMS indicated that a change would require broader supporting evidence than the 34-respondent survey. The G0277 outcome maintains the status quo: HBOT billing infrastructure stays intact, with no recoding of a service central to diabetic foot ulcer and radiation-injury care. For how these interact with the rest of the CY2027 package, see the payment impact overview.

Deep-dive: implications by practice model

For office-based wound practices, 97610 is the item with the largest direct payment effect. The non-facility rate is built largely on the SA119 kit, so the proposed $320.18 → $100 repricing flows almost dollar-for-dollar into the payment; the open question on physician time (6 vs ~15 minutes intraservice) determines whether the work component shrinks too. G0465 staying at 1.78 work RVUs with MPPR applied constrains PRP economics for practices treating multiple diabetic ulcers in one visit. G0277 is not typically an office code, so the HBOT item is mostly neutral here.

CMS has explicitly invited paid invoices to inform the SA119 repricing, and its track record this cycle (see the cystometrogram supplies it declined for unverifiable invoices) shows that documentation weighs heavily in both directions. Given the manufacturer’s own public pricing, the supply input is likely to finalize close to $100. The physician-time question is the less settled component: the 6-minute figure traces to an investor slide deck, a weaker evidentiary basis than the survey data behind the current ~15-minute assumption, so the work component is where the final valuation has the most room to move in either direction.

Mobile and traveling providers deliver wound care wherever the patient resides, from private homes and assisted living to skilled nursing facilities, and the setting determines how this rule’s UltraMIST (97610), PRP (G0465), and HBOT proposals land. The tabs below break out the implications by where the visit occurs.

Mobile providers bill non-facility rates, so the 97610 supply cut applies to them in full, and unlike a fixed clinic, they carry the kit cost plus travel overhead into every encounter. A ~$220 per-treatment supply reduction, potentially compounded by a time cut, could push portable ultrasonic therapy below viability for low-density routes. G0465’s unchanged valuation similarly caps what mobile PRP programs can build, since phlebotomy, centrifugation, and administration all happen at the bedside within a 1.78 work-RVU envelope.

Mobile practices’ per-encounter cost structure (kit price without volume discounts, travel overhead, single-patient visits) diverges most from the assumptions behind the proposed $100 input: the nominator’s implied $86 average likely reflects high-volume purchasers, while small mobile buyers typically pay closer to list price. If the cut finalizes as proposed, portable ultrasonic therapy becomes hardest to sustain in exactly this segment, and the service would tend to retreat toward facility settings, counter to the broader shift of chronic-wound care into homes and residences.

Clinicians rounding in skilled nursing facilities bill the PFS at facility rates for Part B services, so the SA119 supply repricing (a non-facility input) does not directly change their payment for 97610; the risk is indirect, via the physician-time question, since a shortened intraservice time would lower the work RVU component in all settings. G0465 in SNF settings remains constrained by the unchanged 1.78 valuation and MPPR when multiple ulcers are treated the same day, a common scenario in long-stay diabetic populations.

The quiet exposure for SNF-based wound clinicians is the time question on 97610: a cut from ~15 to 6 minutes of intraservice time would ripple into facility-setting payment even though the supply debate does not. SNF residents often present with multiple large, complex wounds, a population where typical treatment time is least likely to match a 6-minute average. The MPPR on G0465 is the other recurring pressure point in this setting; CMS’s “overlapping resource costs” rationale is thinnest where each additional ulcer requires separate preparation and application, which is why the per-wound time-input question, rather than the blanket exemption the nominator sought, is where the analytical dispute actually lands.

Hospital-based outpatient wound centers are paid under OPPS, not the PFS, so the 97610 non-facility cut does not touch their facility payment; in fact, CMS’s stated goal is to close the $179 gap between the $384 office rate and the $205 OPPS rate. The G0277 decision matters most here: hospital wound centers are the main site of HBOT, and keeping the G-code preserves established billing across payment systems. Physician work valuations (99183 attendance, G0465 if furnished) are unchanged.

For wound centers, this section of the rule is largely stabilizing: G0277 retention preserves existing HBOT billing infrastructure, though the RUC’s deletion recommendation remains on the record and could resurface in future cycles. The 97610 physician-time question is the one element that would reach these centers, and only for providers who also furnish the service in office settings. The narrowing office-vs-OPPS differential also reduces the financial incentive to shift ultrasonic therapy out of the hospital, a site-of-service dynamic that runs opposite to the one the current $179 gap creates.

Considerations for providers and manufacturers

Each point below states what CMS proposed and then what it would mean in practice. These are analytical implications, not recommendations; some stakeholders may also weigh them when deciding whether to submit input during the public comment period.

  • Ultrasonic wound therapy (97610) faces a direct per-treatment cut. CMS proposes to drop the SA119 supply input from about $320 to $100, removing roughly $220 of direct practice expense per treatment, and questions whether physician time is closer to ~6 than ~26 minutes, which would compound the reduction. For a practice with UltraMIST volume this is an immediate revenue cut on each treatment; for the manufacturer it resets the reimbursement supporting the consumable model toward the ~$100 cost the device’s own materials cite. CMS invited paid SA119 invoices, so documentable acquisition cost is what determines where the $100 lands.

  • PRP for diabetic wounds retains its current valuation absent new evidence. A nominator asked to raise G0465 work RVUs from 1.78 to 5.50 and exempt it from the multiple-procedure reduction; CMS’s stated objection is that the request rests on a 34-respondent survey. The valuation holds as-is for now; a higher value would require broader work/time evidence in a future cycle. The MPPR question (whether treating several ulcers in one session repeats or shares prep steps like phlebotomy and centrifugation) separately decides whether second-and-subsequent applications are paid in full or halved.

  • Keeping G0277 is a stability signal for HBOT. CMS proposes to retain the hyperbaric-oxygen G-code, so wound programs delivering HBOT face no coding disruption from this item. Relative to the 97610 and PRP items on this page, the payment risk here is low; the item confirms current coding rather than changing it.

The public comment period is open through September 14, 2026 (docket CMS-2026-2377). See How to Comment for the mechanics.

Footnotes

  1. Proposed rule §II.D(12), Ultrasonic Wound Assessment (CPT Code 97610) (CMS-1848-P, 91 FR 43935). CMS states:
    “The CY 2026 non-facility PE RVU of 11.51 for CPT code 97610 results in a payment of $384, compared to an OPPS payment rate of $205, representing a payment differential of $179. The nominator stated that this disparity is primarily driven by the $320 direct PE input, SA119 (kit, low frequency ultrasound wound therapy (MIST)).”↩︎

  2. Proposed rule §II.D(12), Ultrasonic Wound Assessment (CPT Code 97610) (CMS-1848-P, 91 FR 43935). CMS states:
    “On slide 13 of the presentation, it states that the single use applicators are $100 and that the pricing reflects manufacturer’s suggested retail price (MSRP). The nominator also estimated an implied sales price of $86 per disposable kit on average using publicly available manufacturer disclosures and Medicare claims data.”↩︎

  3. Proposed rule §II.D(12), Ultrasonic Wound Assessment (CPT Code 97610) (CMS-1848-P, 91 FR 43935). CMS states:
    “We agree with the nominator and are proposing CPT code 97610 as potentially misvalued. Additionally, we are proposing to change the cost of supply code SA119 to $100 in the direct PE database. We seek comment on this proposal and invite interested parties to submit paid invoices for supply code SA119 (kit, low frequency ultrasound wound therapy (MIST)).”↩︎

  4. CY2027 PFS proposed-rule Potentially Misvalued Codes (PMVC) public use file, memo Options to Address Potential Misvaluation of HCPCS 97610, from The RAND Corporation (Hannah James, Jodi Liu, Lane Burgette) to CMS, dated June 11, 2026. RAND states:
    “CMS asked RAND to identify services that may be misvalued under the Physician Fee Schedule (PFS). This memo examines HCPCS 97610 (low frequency non-contact ultrasound wound management); our analysis suggests that HCPCS code 97610 is potentially overvalued under the Physician Fee Schedule (PFS) due to inflated supply cost inputs.”
    Read the memo (PDF); mirrored from the CMS CMS-1848-P PMVC public use file.↩︎

  5. Proposed rule §II.D(12), Ultrasonic Wound Assessment (CPT Code 97610) (CMS-1848-P, 91 FR 43935). CMS states:
    “We also note that physician time may be currently overstated for CPT code 97610, as the December 2025 Investor Presentation asserts that the procedure takes about 3 to 20 minutes, with an average of 6 minutes.”↩︎

  6. Proposed rule §II.D(12), Ultrasonic Wound Assessment (CPT Code 97610) (CMS-1848-P, 91 FR 43935). CMS states:
    “The current total physician time is nearly 26 minutes, with a work RVU of 0.39. Because the current intraservice time is over double the time asserted by the supply manufacturer in the Investor Presentation, we are seeking comment on whether the typical physician time to perform this service is closer to the manufacturer’s assertion of 6 minutes or the current intraservice time of nearly 15 minutes.”↩︎

  7. Proposed rule §II.D(13), Autologous Platelet Rich Plasma (HCPCS Code G0465) (CMS-1848-P, 91 FR 43935). CMS states:
    “The nominator requested that CMS update the work RVUs for HCPCS code G0465 from 1.78 to 5.50 based on the results of an independent survey of physicians and qualified health professionals who have training and experience treating chronic, non-healing diabetic wounds that was performed by a third party in the Fall of 2025. The nominator also requested that CMS update its policy to state that multiple procedure payment adjustments do not apply to HCPCS code G0465. Additionally, in the CY 2025 PFS Final rule, we finalized crosswalking G0465 to CPT code 15275 (Application of skin substitute graft to face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits, total wound surface area up to 100 sq cm; first 25 sq cm or less wound surface area), however, the nominator believes this is not an appropriate crosswalk for G0465.”↩︎

  8. CY2027 PFS proposed-rule Potentially Misvalued Codes (PMVC) public use file, nomination letter Re: Potentially Misvalued Code HCPCS G0465, from the Alliance of Wound Care Stakeholders to CMS, dated February 6, 2026. The Alliance states:
    “The Alliance of Wound Care Stakeholders (”Alliance”) appreciates the opportunity to request the nomination of HCPCS code G0465 under the Potentially Misvalued Code process. … We request that CMS update the work RVUs for HCPCS code G0465 from 1.78 to 5.50 based on the results of an independent survey of physicians and qualified health professionals who have training and experience treating chronic, non-healing diabetic wounds that was performed by a third party in the Fall of 2025.”
    Read the nomination (PDF); mirrored from the CMS CMS-1848-P PMVC public use file.↩︎

  9. Proposed rule §II.D(13), Autologous Platelet Rich Plasma (HCPCS Code G0465) (CMS-1848-P, 91 FR 43935). CMS states:
    “However, we note the sample size of the survey shows only 34 respondents and so we have concerns as to whether this is a representative sample size of practitioners furnishing this service. Additionally, we continue to believe that the MPPR payment adjustment is applicable to multiple units of this service billed to the same beneficiary on the same day due to overlapping resource costs. Given that no additional information was submitted to support the increase in work RVU, we are not proposing this code as potentially misvalued.”↩︎

  10. Proposed rule §II.D(7), Hyperbaric Oxygen Under Pressure (HCPCS Code G0277) (CMS-1848-P, 91 FR 43932). CMS states:
    “The RUC has requested the deletion of HCPCS code G0277 (Hyperbaric oxygen under pressure, full body chamber, per 30-minute interval), and recommended that CPT code 99183 be revised to be time-based as well to appropriately describe the treatment delivery, attendance and supervision. The RUC concluded that maintaining a separate G-code creates unnecessary coding complexity without adding clinical or administrative value and that one clear and consistent coding structure should exist for this service.”↩︎

  11. Proposed rule §II.B (Practice Expense Methodology) (CMS-1848-P, 91 FR 43844). CMS names the committee as the:
    “American Medical Association (AMA)/Specialty Society Relative Value Scale (RVS) Update Committee (referred to as the RUC).”↩︎

  12. Proposed rule §II.D(7), Hyperbaric Oxygen Under Pressure (HCPCS Code G0277) (CMS-1848-P, 91 FR 43932). CMS states:
    “In 2015, CMS created HCPCS code G0277 to describe direct practice expense inputs associated with CPT code 99183 (Physician or other qualified health care professional attendance and supervision of hyperbaric oxygen therapy, per session). We noted that under the Outpatient Prospective Payment System (OPPS), the treatment used to be reported using separate treatment code C1300 (Hyperbaric oxygen under pressure, full body chamber, per 30-minute interval.) Therefore, we created HCPCS code G0277 to report the treatment delivery and to maintain consistency with the OPPS coding and PFS payment systems.”↩︎

  13. Proposed rule §II.D(7), Hyperbaric Oxygen Under Pressure (HCPCS Code G0277) (CMS-1848-P, 91 FR 43932). CMS states:
    “HCPCS code G0277 was identified as a high-volume growth code that has Medicare utilization of 10,000 or more. High utilization of this magnitude reflects that the code has been broadly adopted across multiple care settings and underscores its operational importance within the Medicare program. Deleting or replacing a high-volume code without an equivalent can disrupt billing practices, create reporting gaps, and impose unnecessary administrative burden on providers who have integrated it into their standard practice.”↩︎

  14. Proposed rule §II.D(7), Hyperbaric Oxygen Under Pressure (HCPCS Code G0277) (CMS-1848-P, 91 FR 43932). CMS states:
    “As such, we believe there is a reason to continue to maintain the use of the G-code for hyperbaric oxygen therapy since HCPCS code G0277 is utilized in multiple Medicare payment systems to report the time the patient uses the hyperbaric oxygen therapy. Accordingly, we are proposing to maintain HCPCS code G0277.”↩︎