Wound Procedures & New Codes

What CMS proposed. For skin cell suspension autograft (SCSA), the CPT Editorial Panel created four new codes (15X19–15X22) and deleted the existing eight SCSA codes (15011–15018); CMS proposes to adopt the work RVUs (10.97, 0.59, 11.28, and 0.98) recommended by the AMA/Specialty Society Relative Value Scale (RVS) Update Committee (the RUC) and the RUC-recommended direct practice expense inputs without refinement. For a new real-time fluorescence wound imaging code (976XX), the RUC recommended contractor pricing, but CMS instead proposes to actively price the service at a work RVU of 0.80 with 26 minutes of total physician time and non-facility direct PE inputs crosswalked from CPT code 97610. CMS also seeks comment on whether 976XX will typically be billed alongside wound debridement codes such as 11042 and 97597, and whether its proposed wound-care supply inputs are duplicative.

Sources: CY2027 PFS proposed rule (CMS-1848-P), §II.D(2) and §II.D(45). See the full rule.

Skin cell suspension autograft (15X19–15X22)

In September 2025, the CPT Editorial Panel restructured the coding for skin cell suspension autograft, the autologous skin cell therapy used for surgical and burn wound closure and increasingly for complex wounds. Four new codes replace the previous eight-code family (CPT codes 15011–15018, now deleted), and the SCSA guidelines were revised.¹ The new codes split by anatomic site (trunk/arms/legs versus face, scalp, hands, feet, genitalia, and other high-complexity sites), with a base code for the first 100 sq cm (or 1% body area in infants and children) and an add-on code for each additional 100 sq cm or 1% body area.² The four new codes were surveyed for the January 2026 RUC meeting.³

For CY 2027, CMS proposes the RUC-recommended work RVUs for all four codes, and the RUC-recommended direct PE inputs without refinement:⁴

Code (placeholder)	Descriptor summary	Proposed work RVU
15X19	SCSA, trunk/arms/legs; first 100 sq cm (or 1% body area, infants/children)	10.97
15X20	SCSA, trunk/arms/legs; each additional 100 sq cm or 1% body area (add-on)	0.59
15X21	SCSA, face/scalp/hands/feet/genitalia and other listed sites; first 100 sq cm (or 1% body area)	11.28
15X22	SCSA, same sites as 15X21; each additional 100 sq cm or 1% body area (add-on)	0.98

The “X” in these code numbers is the rule’s own pre-final CPT placeholder; final code numbers will appear when the CY 2027 CPT code set is released. Compared with much of the proposed rule, where CMS repeatedly rejects RUC recommendations on potentially “misvalued” services, the SCSA proposal is notable for adopting the RUC’s valuations in full.

Real-time fluorescence wound imaging (976XX)

In September 2025, the CPT Editorial Panel created CPT code 976XX (placeholder) for real-time fluorescence wound imaging performed in clinical darkness to identify the presence, location, and load of bacteria and to measure wound size, per day. The specialty society did not survey the code (it determined it could not meet the RUC’s minimum survey threshold), so the RUC recommended contractor pricing for CY 2027.⁵

CMS declined to follow that recommendation. Citing persistent payment variability under the predecessor Category III codes (0598T and 0599T) and limited geographic uptake of the technology, the device manufacturer asked CMS to actively price the code and submitted work RVU and direct PE recommendations. After considering those, CMS proposes:

• A work RVU of 0.80, with 6 minutes pre-service, 15 minutes intraservice, and 5 minutes immediate post-service time: 26 minutes of total physician time.⁶
• Non-facility direct PE crosswalked from CPT code 97610 (low-frequency, non-contact, non-thermal ultrasound, discussed on our “misvalued” services page), plus 10 minutes for a clean surgical instrument package (CA026), for 42 total minutes of clinical labor time.⁷
• Addition of the MolecuLight DX System (ER131) to the direct PE database at a $21,500 purchase price and 5-year useful life. CMS declined to include the device carrying case, applying its longstanding policy that equipment under $500 is treated as indirect expense.⁸

CMS explicitly solicits comment on several points: whether 976XX will typically (more than 50 percent of the time) be billed alongside wound debridement codes such as 11042 and 97597; if so, which proposed supply inputs (a list of twelve items including gloves, gauze, and dressing supplies) duplicate inputs already in the debridement codes; whether wound-care supplies are typical at all for a code whose descriptor covers imaging but no wound-care elements;⁹ and whether 97610 is an appropriate PE crosswalk given differing billing patterns: the predecessor codes 0598T and 0599T were billed with debridement 35.1 and 46.6 percent of the time respectively, while 97610 is billed alone 64.4 percent of the time and with 11042 only 4.3 percent of the time.¹⁰¹¹

Why it matters for wound care

These two proposals move in the same direction: national, active pricing for wound technologies whose coding and payment status was previously unsettled. For SCSA, a consolidated four-code structure with CMS adopting the RUC values as-is establishes predictable payment for autologous skin cell grafting across body sites. For fluorescence imaging, CMS’s decision to actively price rather than leave the code to contractor discretion is the more consequential change: contractor pricing for the predecessor codes produced the payment variability and limited regional coverage that the rule itself acknowledges. A national work RVU and PE profile would let clinicians anywhere bill the service on the same terms.

But the fluorescence proposal comes with an open question that will shape its real-world value: CMS is openly weighing whether the code’s supply inputs overlap with debridement. If CMS removes the wound-care supplies from the final PE inputs, the non-facility payment for 976XX would be meaningfully lower than the proposal implies. For practices that pair imaging with same-day debridement (a common clinical pairing, since fluorescence findings guide where to debride), the resolution of that comment solicitation would directly affect payment. How these values translate into dollars also depends on the conversion factor and efficiency-adjustment machinery covered on our payment impact page.

Deep-dive: implications by practice model

Office-based wound care

For office-based wound specialists, 976XX is the most directly relevant proposal. Active pricing means a billable, nationally consistent code for point-of-care bacterial fluorescence imaging, a service that under 0598T/0599T was often unpaid or inconsistently paid depending on the Medicare contractor. The proposed non-facility PE package (42 minutes of clinical labor, imaging device, and a wound-care supply list) is built on a crosswalk to 97610, and CMS’s own data show 97610 is usually billed alone while the fluorescence predecessors were billed with debridement roughly a third to nearly half the time. The duplicative-supply question therefore bears most directly on office practices: if imaging is typically performed in the same encounter as 11042 or 97597, the supplies CMS lists may be counted twice today and could be removed in the final rule. SCSA matters less day-to-day for office practice, since it is a surgical service, but the adopted values set the reference points for autologous cell therapy in wound closure.

Active pricing of 976XX removes the payment uncertainty that limited the predecessor codes in office settings, but the value of the new code depends on how the supply-overlap question resolves. Imaging and debridement are likely to occur together often, since fluorescence findings guide where to debride; the analytically relevant distinction is between supplies genuinely shared with a same-day debridement and those specific to the imaging service. If the comment record does not separate the two, CMS could treat the entire supply list as duplicative, and the final non-facility PE package would be trimmed on assumption rather than measured overlap.

Mobile wound care

Mobile and traveling wound care providers deliver care wherever the patient resides, from private homes and assisted living communities to skilled nursing facilities. Because the setting changes how the proposed SCSA values and the nationally priced fluorescence imaging code (976XX) actually flow to the rendering clinician, the implications are broken out below by where the visit happens.

Home & residence

Mobile and house-call wound practices bill predominantly in non-facility settings, so the proposed non-facility PE package for 976XX is directly relevant, and the fluorescence device itself is portable, which is why the manufacturer sought national pricing amid limited geographic uptake. A handheld imaging device with a defined equipment input (ER131, $21,500, 5-year life) and a national payment rate makes the economics of transporting one between sites calculable for the first time. CMS declined the carrying case as an equipment input under its $500 threshold, a detail relevant to mobile practices whose cost structure is built around transportable equipment. SCSA is largely out of scope for mobile practice, but the fluorescence code could change what bedside wound assessment includes.

National pricing matters most for practices that span multiple Medicare contractor jurisdictions, and mobile groups fit that profile: they are least able to absorb contractor-by-contractor payment variability across the geographies they cover. One open question is typicality of the supply inputs: imaging at a home or facility bedside may involve a different supply mix than the office-based assumptions underlying the proposed PE package, and CMS’s comment solicitation covers exactly that kind of setting-specific information.

Skilled nursing facility

For clinicians rounding in skilled nursing facilities, the immediate effect is muted: SNF Part A consolidated billing and facility-setting rules mean the non-facility PE package for 976XX generally will not flow to the rendering clinician, and SCSA is a surgical service performed outside the SNF. But the professional work RVU of 0.80 for fluorescence imaging is billable where the service is separately payable, and a nationally priced code removes the contractor-pricing uncertainty that made the predecessor codes impractical in long-term-care settings. The bacterial-load use case is arguably strongest in SNF populations, where chronic pressure injuries and diabetic foot ulcers are prevalent and infection surveillance is a persistent challenge. The debridement-overlap question matters here too, since bedside sharp debridement (97597) is a staple of SNF wound rounds.

In the SNF setting, national pricing alone does not resolve the consolidated-billing and facility-setting constraints that limit separate payment, so the code’s practical value there is likely to depend on evidence that imaging changes management, particularly debridement decisions, rather than on the pricing change itself. The same-day assessment-plus-procedure dynamic also intersects with the E/M and modifier-25 proposals covered on our modifier 25 page, which apply scrutiny to that billing pattern across settings.

Wound care center

Hospital-based outpatient wound centers see these codes through the facility lens: the physician work RVU (0.80 for 976XX; 10.97–11.28 base values for SCSA) drives professional payment, while the non-facility PE package (where most of the 976XX comment solicitation is focused) does not apply to the facility claim. For SCSA, wound centers affiliated with burn and reconstructive programs get a cleaner code family and CMS-adopted values for both base and add-on codes across anatomic sites, including the higher-valued 15X21 for face, hands, feet, and other complex sites. For fluorescence imaging, the professional-side question is whether 26 minutes of physician time and a 0.80 work RVU reflect how the service is actually delivered in a center where clinical staff operate the device. The debridement-overlap solicitation is also relevant to centers: if CMS later builds edits or bundling assumptions around 976XX and 11042/97597, those would reach facility billing patterns as well.

Although the PE controversy is a non-facility issue, its resolution is unlikely to stay confined to non-facility billing. The record CMS assembles now, on how often imaging accompanies debridement and who performs each component, will inform any future bundling and utilization policy, and such policies typically reach facility billing patterns as well. Hospital-based centers are also among the few stakeholders with the volume data to answer CMS’s over-50-percent concurrent-billing question empirically.

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.

• The debridement-overlap answer could reduce separate payment for 976XX. CMS is asking whether fluorescence imaging (976XX) is billed with debridement more than half the time and which supplies duplicate 11042/97597 inputs. If it concludes the overlap is large, it could bundle or discount the imaging payment on debridement days, so a practice adopting 976XX on the expectation of separate same-day payment could find much of that revenue eliminated. A practice’s own 0598T/0599T concurrent-billing rate is effectively the figure CMS is using to decide.

• 976XX’s launch value rests on a labor crosswalk CMS itself questions. CMS builds 976XX’s non-facility practice expense by crosswalking the clinical labor activities and time from CPT 97610, a different wound service, then adds 976XX’s own supply and equipment inputs separately. The crosswalk carries 97610’s labor, not its supplies, so the separate SA119 supply repricing that hits 97610 in this same rule (see “Misvalued” Wound Services) does not automatically flow into 976XX. The more direct exposure is the crosswalk itself: CMS notes 97610 is billed alone 64.4 percent of the time while 976XX’s predecessor codes were frequently billed with debridement, and seeks comment on whether 97610 is an appropriate PE crosswalk at all. A change to 97610’s labor inputs, or a decision to drop the crosswalk, would move 976XX’s launch PE with it.

• Who runs the device decides whether the valuation holds. CMS proposes a 0.80 work RVU and ~26 minutes of physician time for 976XX. If the service is largely delivered by clinical staff, the physician-time assumption is generous and the value is exposed to future downward revaluation; if it is genuinely physician-intensive, it may be durable or even low. For a practice modeling the device’s return, payment durability is contingent on the staffing model CMS ultimately credits.

• SCSA gets a stable value, but new codes mean operational work. CMS adopts the RUC work RVUs and PE inputs for 15X19–15X22 without refinement and deletes the old 15011–15018 series. Practices using autologous skin-cell therapy get a RUC-recommended valuation and a simpler anatomic-site structure; the offsetting reality is that new (still placeholder-numbered) codes require billing-system and payer-edit updates, and the values are only as durable as the RUC survey behind them.

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(2), Skin Cell Suspension Autograft (CPT Codes 15X19, 15X20, 15X21, and 15X22) (CMS-1848-P, 91 FR 43871). CMS states:
   “The existing eight skin cell suspension autograft CPT codes (CPT codes 15011-15018) were deleted, and the “Skin Cell Suspension Autograft” guidelines were revised.”

2. Proposed rule §II.D(2), Skin Cell Suspension Autograft (CPT Codes 15X19, 15X20, 15X21, and 15X22) (CMS-1848-P, 91 FR 43871). CMS states:
   “In September 2025, the CPT Editorial Panel created four codes to report skin cell suspension autograft (SCSA): CPT code 15X19 (Skin cell suspension autograft (SCSA), trunk, arms, and/or legs; first 100 sq cm or less, or 1% of body area of infants and children), […] and CPT code 15X21 (Skin cell suspension autograft (SCSA), face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits; first 100 sq cm or less, or 1% of body area of infants and children) […]”

3. Proposed rule §II.D(2), Skin Cell Suspension Autograft (CPT Codes 15X19, 15X20, 15X21, and 15X22) (CMS-1848-P, 91 FR 43871). CMS states:
   “The four new codes were surveyed for the January 2026 RUC meeting.”

4. Proposed rule §II.D(2), Skin Cell Suspension Autograft (CPT Codes 15X19, 15X20, 15X21, and 15X22) (CMS-1848-P, 91 FR 43871). CMS states:
   “For CY 2027, we are proposing the RUC-recommended work RVUs of 10.97 for CPT code 15X19, 0.59 for CPT code 15X20, 11.28 for CPT code 15X21, and 0.98 for CPT code 15X22. We are proposing the RUC-recommended direct PE inputs for CPT codes 15X19, 15X20, 15X21, and 15X22 without refinement.”

5. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43889). CMS states:
   “In September 2025, the CPT Editorial Panel created a new code to report real-time florescence wound imaging, CPT code 976XX (Real-time fluorescence wound imaging with clinical darkness to identify presence, location, load of bacteria and measure wound size, per day). The specialty society did not conduct a survey for CPT code 976XX because they determined it would be unable to conduct a successful survey that met the RUC’s minimum survey threshold, and therefore, the RUC recommended contractor pricing for CY 2027.”

6. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43889). CMS states:
   “Due to persistent payment variability for the predecessor CPT codes 0598T and 0599T, and limited geographical uptake of the technology, the device manufacturer requested that CMS actively price CPT code 976XX and provided work RVU and direct PE input recommendations. After consideration of the manufacturer’s recommendations, we are proposing a work RVU of 0.80 and physician pre-evaluation time of 6 minutes, intraservice time of 15 minutes, and immediate post service time of 5 minutes, totaling 26 minutes of physician time.”

7. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43889). CMS states:
   “For direct PE in the non-facility, we are proposing a direct crosswalk of clinical labor activities and time from CPT code 97610 ( Low frequency, non-contact, non-thermal ultrasound, including topical application(s), when performed, wound assessment, and instruction(s) for ongoing care, per day ), with the addition of 10 minutes for CA026 Clean surgical instrument package for CPT code 976XX […]”

8. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43890). CMS states:
   “The MolecuLight DX System (ER131) was added to the direct PE database for inclusion in CPT code 976XX assuming a 5-year useful life and purchase price of $21,500 based on the provided invoices. We are not proposing to include the MolecuLight carrying case in CPT code’s 976XX’s equipment costs as recommended by the device manufacturer. We have a longstanding policy that medical equipment must be at least $500 and all equipment inputs under $500 are considered indirect expense.”

9. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43890). CMS states:
   “[W]e are seeking comment on whether the following proposed supply items are duplicative of debridement codes if it is anticipated that these codes will be typically billed together: SB007, SB019, SB044, SC056, SF007, SF018, SG035, SG051, SG052, SG079, SH069 and SJ046. We are also seeking comment on whether these wound care supply items are typical for CPT code 976XX, given that the code descriptor specifies wound imaging but does not include any wound care elements.”

10. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43890). CMS states:
    “We are seeking comment on whether this service will typically be billed alongside wound debridement codes (that is, greater than 50 percent of the time), and if so, which of the proposed direct PE inputs may be duplicative of those already included in the wound debridement codes, such as CPT codes 11042 […] and 97597 […]. We note that CPT code 976XX’s predecessor codes, CPT codes 0598T and 0599T, were billed with wound debridement codes 35.1 percent and 46.6 percent of the time, respectively.”

11. Proposed rule §II.D(45), Real-Time Fluorescence Wound Imaging (CPT Code 976XX) (CMS-1848-P, 91 FR 43890). CMS states:
    “Finally, we note that the direct PE crosswalk code, CPT code 97610, is billed alone 64.4 percent of the time and with debridement CPT code 11042 only 4.3 percent of the time. Therefore, we are seeking comment on the appropriateness of this code as a direct PE crosswalk considering the different billing patterns of CPT code 97610 and 976XX based on its predecessor codes.”