NATROX Wound Care has launched an initiative encouraging wound care clinicians to comment on a proposed Local Coverage Determination (LCD) that would establish Medicare coverage criteria for topical oxygen therapy for certain nonhealing diabetic foot ulcers.

The Durable Medical Equipment Medicare Administrative Contractors (DME MACs) published proposed LCD DL33797 on July 23, 2026. The draft policy would consider topical oxygen therapy reasonable and necessary for Medicare beneficiaries with diabetic foot ulcers that have failed to achieve at least a 50% reduction in ulcer area after 4 consecutive weeks of optimized diabetic foot ulcer care. Because the policy remains in draft form, it has not yet changed Medicare coverage or reimbursement. CMS is accepting public comments through September 5, 2026.

According to NATROX, the company reviewed the proposed LCD in collaboration with the Alliance of Wound Care Stakeholders and identified several areas where the coverage language may benefit from clarification or revision. 

Concerns highlighted by NATROX include: the proposed requirement for a 20% reduction in ulcer area each month to continue coverage, exclusions related to infection and certain comorbidities, monthly in-person visit requirements, reimbursement for topical oxygen therapy supplies, and the lack of a specific definition for “optimized diabetic foot ulcer care.”

To support clinician participation, NATROX has developed a comment template and submission guidance. Clinicians are encouraged to select the issues most relevant to their practice and personalize their comments with their own clinical experience. 

For more information, navigate to www.natroxwoundcare.com/reimbursement 

Editor’s note: This clinician comment initiative and its supporting materials were developed by NATROX Wound Care. NATROX reports that it collaborated with the Alliance of Wound Care Stakeholders in reviewing the proposed coverage language and identifying opportunities for clarification.