Why Measurement Accuracy Suddenly Matters More Than Ever

CMS’s 2026 updates to the Physician Fee Schedule (PFS) and Outpatient Prospective Payment System (OPPS) fundamentally changed how skin substitutes and CAMPS are reimbursed. Payment is now strictly tied to applied surface area, with no reimbursement for unused or discarded material. 

For years, wound measurement was treated as a clinical formality; necessary for documentation, useful for tracking progress, but rarely scrutinized for financial precision. Small inaccuracies were tolerated because they lived inside bundled payment models and opaque reimbursement structures. 

That era is over. 

Under the 2026 CMS updates to the Physician Fee Schedule (PFS) and Outpatient Prospective Payment System (OPPS), reimbursement for skin substitutes and cellular and acellular matrix products (CAMPS) is now explicitly tied to applied surface area, measured in square centimeters. Payment is no longer based on product size, packaging, or clinical intent. It is based on what is actually applied to the patient. 

This change quietly converts wound measurement from a documentation step into a revenue-critical control point. 

In a per-cm² reimbursement model, even modest measurement error compounds quickly. Traditional length × width methods — still widely used in outpatient, office, and mobile settings — have been shown in multiple studies to systematically overestimate true wound surface area, particularly in irregularly shaped wounds. That overestimation routinely ranges from 36% to more than 40%^1 2 when compared with digital planimetry. 

In the past, this bias was mostly invisible. In 2026, it shows up as: 

• Oversized graft selection 

• Increased discarded material 

• Unreimbursed product cost 

• Greater variability across clinicians and sites 

What was once a rounding error has become a direct hit to margin. 

The implications extend beyond cost. When billing is based on applied area, documentation must support why a specific amount of product was used, not simply that a product was used. Inconsistent or subjective measurement increases audit exposure and weakens the clinical narrative that supports appropriate utilization. 

Measurement accuracy is no longer about being precise for precision’s sake. It is about aligning: 

• Clinical decision-making 

• Product utilization 

• Reimbursement rules 

• Compliance expectations 

In short, CMS did not just change how skin substitutes are paid. It changed what matters. 

Practices that continue to rely on estimation will feel the impact slowly; through higher supply costs, lower contribution margins, and uncomfortable questions during audits. Practices that adopt objective, repeatable measurement will gain something more valuable than accuracy alone: control. 

And in the current reimbursement environment, control is the difference between absorbing the change and being disrupted by it. 

CMS Pays in 2D. Wounds Exist in 3D. 

While reimbursement is based on surface area, wounds are not flat. 

They are three-dimensional biological environments with depth, contour, undermining, and mechanical forces acting on them from the moment the patient stands, walks, or shifts in bed. 

Clinicians must account for: 

• Depth and tissue loss, which affect graft contact and integration 

• Irregular edges and undermining, where a surface measurement alone understates true coverage needs 

• Shear forces, especially in mobile or weight-bearing locations 

• Fixation requirements, where insufficient edge contact leads to lift, fluid accumulation, and failure 

This is why skin substitutes are intentionally applied slightly beyond the visible wound edge. That extension is not excess — it’s what allows the graft to conform, adhere, and remain viable long enough to do its job. 

Surgical and wound care literature consistently emphasizes the importance of secure edge contact and fixation to promote graft viability and healing.³

When overlap is insufficient, the downstream consequences are predictable: 

• Early graft failure 

• Increased drainage and edge maceration 

• Repeat applications 

• Higher total product utilization over time 

Ironically, too little overlap often results in more total spend, not less. 

At the same time, CMS does not reimburse for unused or discarded material. That creates a tension point clinicians now feel acutely: 

• Apply too little, risk failure. 

• Apply too much, absorb the cost. 

This is where precision becomes essential. 

Accurate edge detection and surface area measurement allow clinicians to: 

• Plan minimum effective overlap rather than guessing 

• Match product size to what will actually be applied 

• Extend coverage intentionally for fixation while minimizing discard 

• Document why applied surface area exceeds the visible wound bed 

Depth measurement, while not a billing unit, plays a critical supporting role here. It provides the clinical justification for overlap in deeper or contoured wounds and explains why flat surface math alone is insufficient. CMS may pay in two dimensions, but auditors still expect the medical record to reflect three-dimensional clinical reality. 

The goal is not to flatten clinical judgment into a formula. 
It’s to make clinical decisions measurable, repeatable, and defensible in a payment model that no longer tolerates approximation. 

CMS pays in 2D. 
Wounds heal in 3D. 
Precision is how you reconcile the two. 

From Eyeballing to Protocol 

The goal under 2026 CMS policy is not to eliminate overlap, but to standardize it. 

Objective digital measurement enables: 

• Accurate wound edge detection 

• Consistent calculation of applied surface area 

• Planned, minimal overlap tied to clinical need 

• Defensible documentation aligned with CMS payment logic 

Depth measurement, while not a billing unit, remains essential for justifying fixation and overlap decisions in the medical record. 

Precision Is the New Compliance Strategy 

Practices that continue to rely on subjective estimates will experience: 

• Increased unreimbursed product loss 

• Greater variability across clinicians 

• Higher audit exposure 

A minor miscalculation in wound area, a casual estimate of overlap, or a generic note in the chart is no longer trivial — it directly affects reimbursement, audit defensibility, and clinical outcomes. 

Precision does three things at once: 

1. Protects margins: Accurate measurement ensures you only open and bill for what is applied, reducing wasted product and lost revenue. 

2. Defends clinical judgment: When overlap is documented objectively and tied to wound geometry and depth, the clinician’s rationale is transparent, reproducible, and defensible. 

3. Strengthens audit posture: Objective, repeatable methods — especially digital or AI-assisted measurement — create a clear audit trail that meets CMS expectations. 

Put bluntly: the future of compliance isn’t “check the box.” It’s having a repeatable, measurable, and defensible workflow that aligns clinical excellence with reimbursement rules. In this environment, precision is no longer optional — it is your frontline compliance strategy. 

Final Thought 

CMS’s 2026 reforms didn’t change how wounds heal. 
They changed how mistakes are paid for. 

Clinicians still decide: 

• How much overlap is necessary 

• How to accommodate depth and contour 

• How to secure fixation 

AI, digital measurement, and objective workflows don’t replace that expertise — they protect it, making each clinical choice measurable and justifiable in a world where applied cm² drives payment. 

The consequences of inaccuracy are real: unreimbursed material, repeat procedures, audit exposure, and margin erosion. But the practices that adopt precision as a habit — measuring, documenting, and planning every cm² — will not just survive. They will lead the shift, delivering better care, fewer surprises, and stronger financial outcomes. 

Overlap is clinically necessary. Waste is optional. Precision is the difference. 

1. Rogers LC et al. Comparison of Wound Measurement Techniques. J Am Podiatr Med Assoc. 2010. ↩︎
2. Wang C et al. Manual Versus Digital Measurement of Chronic Wounds. Int Wound J. 2023. ↩︎
3. Elseth A, Nunez Lopez O. Wound Grafts. [Updated 2025 Feb 15]. In: StatPearls [Internet]. Treasure Island (FL): StatPearls Publishing; 2025 Jan ↩︎