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Medicare LCD Wound Care 2026: MAC-by-MAC Policy Reference

Complete MAC-by-MAC LCD reference for wound care — which Local Coverage Determinations apply in your jurisdiction, coverage differences, and how to find your MAC's specific requirements.

D

Damon Ebanks

Medipyxis

Medicare LCD Wound Care 2026: MAC-by-MAC Policy Reference

Why Your MAC Determines Your Wound Care Revenue

A wound care claim that pays in Georgia may deny in Ohio. The same CPT code, the same diagnosis, the same documentation -- different MAC, different outcome. Local Coverage Determinations are issued by individual Medicare Administrative Contractors, and each MAC has its own policies governing which wound care services are covered, what documentation is required, and how frequently a service can be performed.

If you operate in a single state, you need to know one MAC's requirements. If you treat patients across state lines -- common in mobile wound care, SNF-based practices, and telehealth -- you need to know every MAC whose jurisdiction touches your patient population. The MAC is determined by the patient's state of residence for Part B claims, not by where your practice is incorporated.

This reference maps every MAC jurisdiction, identifies the wound care LCDs that apply in each, and highlights the policy differences that affect your billing.


The Seven Medicare Administrative Contractors

CMS contracts with seven MACs to process Part A and Part B claims across the country. Each MAC operates within assigned jurisdictions, and each jurisdiction covers specific states. Here is the complete map for 2026.


CGS Administrators

Jurisdictions: J6, J15

States covered:

  • J15: Kentucky, Ohio
  • J6: Illinois, Minnesota, Wisconsin

Key wound care LCDs:

L33831 -- Wound Care and Skin Substitute Products. This is the primary LCD governing skin substitute application in CGS jurisdictions. It specifies covered ICD-10 diagnosis codes, requires documentation of failed conservative therapy (minimum 30 days), mandates serial wound measurements demonstrating non-healing, and limits application frequency to weekly intervals. The companion Article (A52948) includes the covered CPT/HCPCS code list and product-specific billing guidance.

L33728 -- Debridement Services. Covers selective (97597/97598) and excisional (11042-11047) debridement. Requires documentation of wound bed condition necessitating debridement, depth of tissue removed, and clinical rationale for the chosen debridement method.

Key requirements specific to CGS:

  • Conservative therapy must be documented with specific dates, interventions, and outcomes -- not just a statement that conservative care was tried
  • Wound measurements must include length, width, and depth at every visit
  • Vascular assessment (ABI or equivalent) required for all lower extremity wounds before advanced therapy

First Coast Service Options

Jurisdictions: J9, JN

States covered:

  • JN: Florida, Puerto Rico, U.S. Virgin Islands
  • J9: Florida, Puerto Rico, U.S. Virgin Islands

Key wound care LCDs:

First Coast administers both Part A and Part B in this jurisdiction. Florida is one of the highest-volume wound care markets in the country due to its large Medicare population, high diabetes prevalence, and concentration of SNFs and home health agencies.

L36690 -- Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. Specifies covered wound etiologies, product categories, documentation requirements, and frequency limits. Notably, First Coast has maintained more detailed LCD guidance than some MACs that withdrew their skin substitute LCDs in early 2026.

L36400 -- Wound Care. General wound care LCD covering debridement, wound assessment, and dressing selection. Documentation must demonstrate medical necessity for each service billed, including wound etiology, infection status, and prior treatment response.

Key requirements specific to First Coast:

  • Diabetic foot ulcers require documented HbA1c within 90 days of treatment initiation
  • Venous leg ulcers require documented trial of compression therapy before advanced treatments
  • Photographs are strongly recommended (though not formally required) -- First Coast auditors routinely request them

National Government Services (NGS)

Jurisdictions: J6, JK

States covered:

  • JK: Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, Vermont

Key wound care LCDs:

L35041 -- Wound Care. Covers wound care services including debridement, wound assessment, and skin substitute application for the Northeast corridor. Documentation requirements include wound etiology, duration, measurements, and prior treatment history.

Key requirements specific to NGS:

  • NGS requires a clear statement of medical necessity linking the wound type to the specific treatment performed
  • Documentation of patient comorbidities that affect healing (diabetes, PVD, immunosuppression) must appear in each visit note, not just the initial evaluation
  • NGS has been active in post-payment audits for wound care services -- practices in this jurisdiction should expect documentation scrutiny

Novitas Solutions

Jurisdictions: JH, JL

States covered:

  • JH: Arkansas, Colorado, Delaware, Washington D.C., Louisiana, Maryland, Mississippi, New Jersey, New Mexico, Oklahoma, Pennsylvania, Texas
  • JL: Delaware, Washington D.C., Maryland, New Jersey, Pennsylvania

Key wound care LCDs:

L37166 -- Application of Skin Substitute Grafts for Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. One of the most detailed wound care LCDs in the system. Defines covered wound etiologies (DFU and VLU only -- other chronic wound types may not be covered for skin substitute application), medical necessity criteria, comprehensive documentation requirements, and restrictions on concurrent product use.

L37165 -- Wound Care Services. Covers debridement and general wound management. Includes specific documentation standards for each debridement code level.

Key requirements specific to Novitas:

  • L37166 restricts skin substitute coverage to DFU and VLU -- practices treating pressure injuries or surgical wounds with skin substitutes in Novitas jurisdictions should verify coverage carefully
  • Requires documentation that the wound has been present for a minimum of 30 days with no measurable improvement despite conservative care
  • The conservative care trial must include specific interventions appropriate to wound type (offloading for DFU, compression for VLU)
  • Novitas covers the largest geographic territory of any MAC -- practices in Texas, Pennsylvania, and the mid-Atlantic states all fall under this jurisdiction

Palmetto GBA

Jurisdictions: JJ, JM

States covered:

  • JJ: Alabama, Georgia, Tennessee
  • JM: North Carolina, South Carolina, Virginia, West Virginia

Key wound care LCDs:

L38720 -- Wound Care. Covers debridement services and skin substitute application. Includes covered diagnosis lists, conservative treatment requirements, wound bed preparation criteria, and per-visit documentation standards.

Key requirements specific to Palmetto:

  • Wound bed preparation must be documented before skin substitute application -- debridement of the wound bed should occur at the same visit or immediately prior
  • Per-visit documentation must include wound bed description (granulation percentage, necrotic tissue, exudate type and amount)
  • Palmetto has published detailed wound measurement guidelines -- measurements must be taken using a consistent method and documented in centimeters

WPS Government Health Administrators

Jurisdictions: J5, J8

States covered:

  • J5: Iowa, Kansas, Missouri, Nebraska
  • J8: Indiana, Michigan

Key wound care LCDs:

L35086 -- Wound Care. Covers debridement and wound management services. Documentation requirements align with general Medicare medical necessity standards but include specific expectations for wound measurement documentation and treatment plan updates.

Key requirements specific to WPS:

  • Treatment plan must be documented at the initial wound care visit and updated when the plan of care changes -- not just a recurring note template
  • Serial wound measurements must demonstrate a healing trajectory or document the clinical rationale for continued treatment in the absence of measurable improvement
  • WPS has historically been one of the more documentation-focused MACs for wound care services

Noridian Healthcare Solutions

Jurisdictions: JE, JF

States covered:

  • JE: Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming
  • JF: Alaska, American Samoa, Arizona, California, Guam, Hawaii, Idaho, Montana, North Dakota, Northern Mariana Islands, Nevada, Oregon, South Dakota, Utah, Washington, Wyoming

Key wound care LCDs:

L36384 -- Wound Care. Covers wound care services across the Western states and Pacific territories. Noridian's wound care LCD includes specific language around wound chronicity definitions and documentation of healing failure.

Key requirements specific to Noridian:

  • Noridian defines a chronic wound as one that has failed to progress through the normal phases of healing within 30 days -- documentation must address this threshold explicitly
  • For skin substitute applications, the wound must be documented as having a clean, granulating wound bed free of necrotic tissue and clinical infection
  • Noridian covers the largest geographic area including several rural and frontier states -- telehealth wound care documentation requirements may differ from in-person visit expectations

How to Determine Your Patient's MAC

The MAC that processes a Part B wound care claim is determined by the state where the service is rendered, not the patient's home address and not your practice's billing address. For most wound care scenarios, this is straightforward -- the patient is treated in the state where they live.

It gets complicated in three situations:

Border communities. A patient who lives in Virginia (Palmetto GBA, JM) but receives wound care at a SNF in Maryland (Novitas, JL) has their claim processed by Novitas, not Palmetto. You must meet Novitas documentation standards, not Palmetto's.

Mobile practices across state lines. If your mobile wound care practice serves patients in both Georgia (Palmetto, JJ) and Tennessee (Palmetto, JJ), you are within a single MAC. But if you cross into Alabama (also Palmetto, JJ) or Florida (First Coast, JN), the MAC changes and so do the LCD requirements.

Telehealth. For telehealth wound care services, the place of service is the patient's location at the time of the encounter. A telehealth follow-up for a patient sitting in their home in Texas falls under Novitas, regardless of where the provider is located.

Always verify the MAC jurisdiction for each patient before the first visit. The CMS MAC jurisdiction lookup tool identifies the MAC by state.


Key Policy Differences Between MACs

While all MACs require medical necessity documentation, the specific requirements vary in ways that directly affect claim outcomes.

RequirementCGSFirst CoastNGSNovitasPalmettoWPSNoridian
Conservative care trial (days)30303030303030
ABI/vascular assessment requiredYes (LE)Yes (LE)RecommendedYes (LE)Yes (LE)RecommendedYes (LE)
HbA1c documentation for DFURecommendedRequired (90 days)RecommendedRecommendedRecommendedRecommendedRecommended
Wound photographyRecommendedStrongly recommendedRecommendedRecommendedRecommendedRecommendedRecommended
Skin substitute LCD active (2026)RevisedActiveRevisedActiveRevisedRevisedRevised
Covered wound types for CTPDFU, VLU, chronicDFU, VLUDFU, VLU, chronicDFU, VLU onlyDFU, VLU, chronicDFU, VLU, chronicDFU, VLU, chronic

The most operationally significant difference is in covered wound types for skin substitute application. Novitas explicitly limits coverage to diabetic foot ulcers and venous leg ulcers. Other MACs cover a broader range of chronic non-healing wounds. A practice that routinely applies skin substitutes to pressure injuries and operates in a Novitas state needs to verify coverage before every application.


Multi-State Practice Considerations

Practices operating across multiple MAC jurisdictions need a compliance strategy that accounts for policy differences without creating unsustainable administrative complexity.

Document to the strictest standard. If one of your MACs requires vascular assessment and another only recommends it, document vascular assessment for every lower extremity wound patient. Documenting to the highest standard across all jurisdictions eliminates the risk of applying the wrong MAC's requirements to the wrong patient.

Maintain MAC-specific code sets. The covered diagnosis code lists vary between MACs. A diagnosis code that is covered under one MAC's LCD may not appear on another's list. Your billing system should flag the MAC jurisdiction and validate codes against the applicable LCD before claim submission.

Track LCD revisions by MAC. LCDs are revised independently by each MAC. A change in one jurisdiction does not automatically mean a change in another. Subscribe to LCD update notifications from each MAC that processes your claims.


How to Track LCD Changes

LCDs are revised without advance notice at any time. The CMS Medicare Coverage Database publishes all LCD changes, but it does not push notifications. Practices must actively monitor for changes.

CMS Medicare Coverage Database (medicare.coverage.cms.gov). Search by LCD number, keyword, or CPT/HCPCS code. Each LCD entry includes the revision history and effective dates.

MAC websites. Each MAC publishes LCD updates on its website and typically offers an email notification list. Subscribe to every MAC that processes your claims.

CMS HCPCS Quarterly Updates. Code changes (additions, deletions, revisions) that affect LCD applicability are published quarterly. Check these in January, April, July, and October.

The operational cost of missing an LCD revision is a denial pattern that may persist for weeks or months before you identify the cause. Systematic monitoring is cheaper than retroactive appeals.

For more on LCD compliance strategy, see our LCD compliance guide, the 2026 LCD overview, and our skin substitute billing reference.

Want to learn more about Medipyxis?

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