Wound Care LCD 2026: Your MAC's Coverage Policy Explained

If you bill wound care to Medicare, you bill against a Local Coverage Determination. The LCD your practice follows depends on which Medicare Administrative Contractor (MAC) processes claims for the state where services are rendered. Each MAC publishes its own LCD with its own covered diagnosis list, documentation requirements, frequency limits, and utilization criteria. A claim that meets one MAC's LCD can be denied under another's.

This reference covers the 2026 wound care LCDs by MAC, what changed this year, and where the policies diverge in ways that affect how you document and bill.

For background on what an LCD is and how it differs from an NCD, see our LCD fundamentals guide.

What Changed in 2026

The 2026 LCD revision cycle brought targeted updates across all three primary wound care LCDs. The changes reflect CMS's ongoing scrutiny of skin substitute utilization, tighter documentation expectations for debridement, and revised NPWT coverage criteria.

Skin substitute coverage tightening. All three MACs narrowed the conditions under which cellular and tissue-based products (CTPs) are covered. CGS and Novitas both added explicit language requiring documented failure of at least 30 days of conservative wound therapy before CTP application is billable. Palmetto already required this but added wound measurement trajectory requirements -- the wound must show less than 30% reduction in area over the conservative therapy period to qualify.

Debridement documentation specificity. CGS L33831 and Novitas L37166 now require documentation of the deepest tissue layer removed at the time of debridement, not just the wound depth at presentation. This directly affects whether a practice can support excisional debridement codes (11042-11047) versus selective codes (97597-97598) on audit.

NPWT coverage duration. Palmetto L38720 revised its negative pressure wound therapy coverage period from indefinite-with-reassessment to a defined initial authorization of 30 days with documented reassessment required for continuation. CGS and Novitas maintain their existing reassessment intervals but added language requiring wound measurement comparison between NPWT initiation and each reassessment.

ICD-10 code list updates. All three LCDs updated their covered diagnosis code lists for 2026 ICD-10-CM revisions. Several chronic ulcer codes were reclassified, and practices billing against 2025 code lists will see denials on reclassified codes. Cross-reference your diagnosis codes against the current LCD Article for your MAC before submitting claims.

MAC-by-MAC Breakdown

CGS Administrators -- L33831 (Jurisdictions 6 and 15)

States covered: Illinois, Indiana, Kentucky, Michigan, Minnesota, Ohio, Wisconsin, Iowa, Kansas, Missouri, Nebraska.

CGS takes the most granular approach to wound measurement documentation. The 2026 revision requires length, width, and depth at every visit with wound bed description including percentage of tissue types present. CGS specifies that wound measurements must use a consistent methodology across visits -- switching between linear and tracing-based measurement within a wound episode is flagged during audit.

Skin substitute frequency limit: one application per wound per week, with a maximum of 12 applications per wound episode before additional documentation of medical necessity is required.

Debridement: CGS requires documentation of the instrument used, tissue type removed, and post-debridement wound bed status. Selective debridement must specify the method (wet-to-dry, enzymatic, autolytic, sharp selective) and cannot simply state "debridement performed."

Novitas Solutions -- L37166 (Jurisdictions 2, 3, 4, and 12)

States covered: Alaska, Arizona, California, Hawaii, Nevada, Oregon, Washington, American Samoa, Guam, Northern Mariana Islands, Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, Vermont, Delaware, District of Columbia, Maryland, New Jersey, Pennsylvania.

Novitas covers the largest geographic footprint and maintains the most detailed treatment history requirements. The 2026 revision requires documentation of all wound care modalities attempted before advanced therapy, with dates and outcomes for each. A note stating "conservative therapy failed" without specifics does not satisfy the LCD.

Skin substitute frequency limit: one application per wound per 7-day period. Novitas is stricter on concurrent product use -- applying two different CTP products to the same wound in the same episode requires separate medical necessity documentation for each.

Debridement: Novitas requires pre- and post-debridement wound measurements and photographic documentation when excisional debridement is performed. The 2026 revision added a requirement that the medical record distinguish between debridement performed as a standalone service versus debridement performed as wound bed preparation prior to CTP application.

Palmetto GBA -- L38720 (Jurisdictions 1 and 11)

States covered: Alabama, Florida, Georgia, Tennessee, North Carolina, South Carolina, Virginia, West Virginia.

Palmetto maintains the most structured wound bed preparation criteria. Before a skin substitute is covered, the wound must be free of necrotic tissue, have adequate vascular supply documented by clinical assessment, and show no signs of active infection. The 2026 revision added a requirement for documented vascular assessment -- either ABI, toe pressure, or clinical pulse assessment -- within 90 days of initial CTP application for lower extremity wounds.

Skin substitute frequency limit: one application per wound per week, maximum of 16 applications per wound episode. Palmetto allows more total applications than CGS but enforces stricter wound progression criteria -- if the wound has not decreased in size by 10% after 4 applications, continued CTP use requires a documented reassessment and revised treatment plan.

Debridement: Palmetto requires wound bed description before and after debridement, including percentage of granulation, slough, eschar, and any exposed structures. The clinical note must support the tissue depth billed.

NGS (National Government Services) -- Jurisdictions 6 and K

States covered (as MAC for Part B): Connecticut, Illinois, Maine, Massachusetts, Minnesota, New Hampshire, New York, Rhode Island, Vermont, Wisconsin.

NGS does not maintain a standalone wound care LCD equivalent to the three above. Practices in NGS jurisdictions follow general Medicare coverage criteria and should reference CMS national guidance plus any applicable NGS Local Coverage Articles for specific procedure codes. Where NGS jurisdiction overlaps with CGS or Novitas territory (this occurs because Part A and Part B MACs can differ), practices must identify which MAC adjudicates the specific claim type and follow that MAC's LCD.

Quick Reference: MAC Coverage Comparison

MAC	Jurisdictions	LCD Number	Conservative Tx Requirement	CTP Frequency Limit	Max CTP Applications	Debridement Photo Required
CGS	J6, J15	L33831	30 days documented failure	1 per wound per week	12 per episode	Not required
Novitas	J2, J3, J4, J12	L37166	30 days with modality detail	1 per wound per 7 days	Per medical necessity	Required for excisional
Palmetto	J1, J11	L38720	30 days + <30% area reduction	1 per wound per week	16 per episode	Not required (wound bed % required)
NGS	J6, JK	No standalone LCD	Per national guidance	Per national guidance	Per national guidance	Per national guidance

Documentation Requirements That Differ Between MACs

The most common audit findings are not clinical errors but documentation gaps. These are the elements where MAC policies diverge and multi-state practices most frequently fail:

Wound measurement methodology. CGS requires consistent methodology across the episode. Novitas and Palmetto do not explicitly mandate consistency but auditors compare measurements across visits, and methodology changes create apparent inconsistencies.

Vascular assessment. Palmetto requires documented vascular assessment within 90 days for lower extremity wounds before CTP application. CGS and Novitas require documentation of vascular adequacy but do not specify a formal assessment method or timeframe.

Prior treatment history specificity. Novitas requires the most detailed treatment history -- each modality, dates of use, and outcome. CGS requires documentation of failed conservative therapy but accepts less granular detail. Palmetto falls between the two.

Debridement standalone vs. pre-graft. Novitas uniquely requires the record to distinguish whether debridement was performed as a standalone therapeutic service or as wound bed preparation prior to CTP application. This distinction affects whether debridement and CTP application on the same date of service are separately billable.

For detailed billing guidance on skin substitute codes affected by these LCDs, see our skin substitute billing guide.

How to Look Up Your MAC

Your MAC is determined by the state where the service is rendered, not the state where your practice is incorporated or where the patient resides.

Go to the CMS MAC lookup page at cms.gov/Medicare/Medicare-Contracting/Medicare-Administrative-Contractors.
Identify your state and the claim type (Part A vs. Part B).
Note the MAC name and jurisdiction number.
Search the CMS Medicare Coverage Database (medicare.coverage.cms.gov) for that MAC's wound care LCD by LCD number or by searching "skin substitute" or "wound care" filtered to the relevant jurisdiction.

Practices operating across multiple states may fall under different MACs. Each claim must meet the LCD requirements for the MAC that adjudicates that claim -- there is no reciprocity between MAC coverage policies.

Frequently Asked Questions

Do LCD requirements apply to Medicare Advantage plans? Not directly. Medicare Advantage (MA) plans can set their own medical necessity criteria. However, many MA plans reference or adopt the local MAC's LCD as their baseline coverage policy. Check the MA plan's provider manual for wound care coverage criteria. Some require prior authorization where original Medicare does not.

What happens if my MAC updates the LCD mid-year? The revised LCD supersedes the prior version on its effective date. Claims submitted after the effective date are adjudicated against the new version regardless of when the service was rendered. Monitor your MAC's LCD revision notices -- CMS publishes proposed changes with a comment period before finalizing.

Can I appeal a denial based on LCD criteria? Yes. LCD-based denials follow the standard Medicare appeals process: redetermination, reconsideration by a QIC, ALJ hearing, Medicare Appeals Council, and federal court. The appeal must demonstrate that the service met LCD criteria -- submitting additional documentation that was not in the original record is permissible at appeal but does not change the underlying documentation gap that caused the denial.

My practice operates in two states under different MACs. Do I need two different documentation workflows? In most cases, yes. If the LCDs differ on required documentation elements, your notes must satisfy the stricter standard for each MAC or you need state-specific documentation templates. The safest approach is to document to the most stringent LCD across all your MACs -- if your notes satisfy Novitas requirements, they will generally satisfy CGS and Palmetto as well.