Comment on CMS-2026-2377-0002

As a healthcare provider operating within a skilled nursing facility, I am writing to strongly oppose the proposed reimbursement reductions for CPT code 97610 outlined in the CY 2027 Medicare Physician Fee Schedule Proposed Rule.Utilizing this woundmist technology has been the exact change agent we have been looking for to treat our most vulnerable patients suffering from severe, chronic wounds. This year alone, this technology has successfully healed over 22 stage 4 wounds in our facilities. If finalized, the proposed rate reductions will make this highly effective modality financially unusable in the SNF setting, virtually guaranteeing that our patients will continue to suffer from debilitating wounds.Discrepancies in Real-World Costs vs. CMS Estimates. I have reviewed the justification for the proposed cuts, including the June 11, 2026, document titled Mist Memo hcpcs97610_memo_20260611.pdf. The memo relies on publicly sourced estimates and manufacturer investor presentations that simply do not reflect the reality of operating in a modern SNF setting. My facility's actual costs starkly contradict the memo's estimates. Capital Equipment Costs: The memo references a manufacturer presentation estimating a $35,000 acquisition cost for the UltraMIST system. In reality, the device costs our facility $60,000. Disposable Applicator Costs: The memo suggests reducing the disposable kit supply cost to $86 or $100 per service, based on estimated sales prices and list prices. We actually pay $125 per applicator. Proposed Payment Alignment: The memo proposes capping the nonfacility practice expense payment to align with the Hospital Outpatient Department (OPPS) rate of approximately $205 to $217. At a rate this low, we would operate at a severe loss before even factoring in overhead, maintenance, and clinical labor. In addition to supply costs, CMS is questioning the physician and provider time currently assigned to CPT 97610, citing a manufacturer presentation suggesting that active treatment averages only 6 minutes. This narrow view ignores the complete episode of care required to safely and effectively administer this therapy.In our SNF, physical therapy (PT) labor costs us $80 per hour. The active treatment time represents merely a fraction of the total clinical workflow. A standard session mandates: thorough patient assessment and wound preparation, previous dressing removal and sterile treatment setup, active device application, post-treatment wound care, including compression therapy and complex dressing application, meticulous clinical documentation and breakdown. If these proposed cuts are finalized, the math is simple: the modality becomes entirely unusable in our setting, and patient access to life-changing wound care will be drastically reduced.The RAND analysis estimating an implied sales price of $86 per kit relies heavily on broad assumptions about Medicare claim lines and the distribution of devices among unique billing providers. These assumptions fail to capture the true economic burden on individual SNFs that pay a premium for capital equipment, supplies, and highly skilled PT labor to manage complex wounds. I strongly urge CMS to evaluate actual provider invoices—not just manufacturer investor presentations or extrapolated claims data—before finalizing the CY 2027 Physician Fee Schedule. Please do not finalize reductions that will directly result in increased suffering for patients with chronic wounds.Thank you for your time, consideration, and commitment to preserving patient access to necessary care.