1. The Spending Explosion Demands Immediate Action

The numbers don't lie, and they're terrifying. Medicare Part B expenditures for skin substitutes have skyrocketed over the last 2 years, surpassing $10 billion annually by the end of 2024. The numbers for 2025 may even shock the product companies when the final spending is tallied! This isn't sustainable, and the government knows it.

What this means for you: The days of business-as-usual are over. Audits, reviews, and pre-authorization pilot programs like WISER are the new normal. Centers that haven't invested in robust compliance programs will be sitting ducks when the inevitable audits arrive. The smart money is on preparation, not panic.

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2. Patient Migration is Coming- Are You Ready?

Here's where opportunity meets preparation. As questionable practices get shut down and regulatory pressure mounts, legitimate wound centers will see an influx of patients seeking quality care.

The reality: High-complexity diabetic patients, post-surgical wound complications, and chronic ulcers require specialized care. Centers with strong clinical outcomes and compliance will become the top choice. Many hospital-based wound centers already treat patients who have exhausted skin substitute limits yet remain unhealed. These efficient, compliant centers will persist in their mission amidst rising fraud, waste, and abuse—saving limbs and lives.

WCA insight: Our network centers are already preparing for capacity expansion. When patient migration happens, and it will due to abandoned patients, you want to be the solution, not another casualty.

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3. Fraud Identifiers: Know the Warning Signs

The OIG report highlighted some eye-opening patterns. Among enrollees with a skin substitute claim, costs for those reportedly treated at home were four times as high as those treated in an office setting. That's a red flag the size of a billboard.

Critical markers the OIG is watching:

• Unusual billing patterns for home-based care.
• Providers suddenly appear in the system with massive volume.
• Claims lacking proper medical necessity documentation.
• Providers submitting multiple skin substitute claims on the same date to bypass Medicare's $99,999.99 claim limit.
• Using skin substitutes for unapproved conditions (e.g., minor scrapes or blisters) or in excessive amounts for the condition (e.g., total body surface treatments).
• Frequent use of skin substitutes during patients' first visits without trying conservative treatments first.
• Providers in specialties unrelated to skin treatment (e.g., neurologists or psychiatrists) billing for skin substitutes.
• Patterns that suggest spread pricing abuse.

What Wound Centers Need to Know:

• Stay informed about the proposed Local Coverage Determination (LCD) on skin substitutes. If implemented next year, it may limit the number of reimbursable products.
• Thoroughly review the documentation requirements and ensure your electronic medical records (EMR) comply with these criteria.
• Refrain from purchasing excessive quantities of products.
• Select products backed by peer-reviewed clinical studies proving efficacy.
• Administer products appropriately based on provider judgment.
• Ensure medical necessity per current LCD guidelines.
• Avoid collaborating with individuals who promise patient referrals in exchange for product usage. Report such incidents to the OIG Fraud Hotline.

Your protection: Bulletproof documentation, transparent billing practices, and clinical protocols that stand up to scrutiny.

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4. Compliance Isn't Just Nice to Have- It's Your Lifeline

Every wound center needs a compliance program that works in real-time, not just during or after an audit. The regulations governing wound care are stricter than most specialties, and ignorance isn't a defense.

This is where tools like Luvo become essential. Our platform doesn't just track compliance- it actively helps you maintain it. Real-time regulatory updates, documentation review, authorization screening, and direct access to experts who understand what auditors are looking for.

Bottom line: Centers with comprehensive compliance programs will not only survive the coming scrutiny, they'll use it as a competitive advantage.

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5. Act Now or Get Left Behind

The regulatory environment is shifting whether you're ready or not. CMS is proposing to pay for skin substitutes as incident-to supplies, a change expected to reduce spending on these products by nearly 90%.

What separates survivors from casualties:

• Proactive compliance investment
• Clinical excellence and documented outcomes
• Efficient operations that don't rely on questionable practices
• Strategic partnerships with proven support networks

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The WCA Advantage: Built for Times Like These

For over two decades, WCA has been helping wound centers navigate regulatory challenges while delivering exceptional patient care. Our Six Rules philosophy puts patient care first, but we back it up with the tools and expertise you need to stay compliant and profitable.

WCA’s Proprietary Luvo platform isn't just software- it's your early warning system, compliance coach, and business intelligence platform all in one. While others scramble to understand new regulations, WCA centers with Luvo get real-time updates and actionable guidance from real industry experts on call 24/7. Clinical, operational, billing, coding, and compliance specialists are on site and on call for your facility providing the support every wound center needs in a cost-conscious way.

The stakes have never been higher, but neither has the opportunity. Wound centers that take decisive action now will emerge stronger, more profitable, and better positioned to serve the patients who need us most.

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Your Next Move

The OIG report isn't just a warning- it's a roadmap. Smart centers are already taking action. The question isn't whether change is coming; it's whether you'll be ready for it.

Don't wait for an audit to discover your documentation gaps. Don't hope the regulatory storm will pass you by. And definitely don't assume that good intentions are enough in today's environment.

Ready to turn this challenge into your competitive advantage? Let's talk about how WCA and Luvo can help you not just survive the coming changes, but thrive because of them.

Contact us at 888-484-3922 or visit thewca.com to learn how the industry's leading wound care support network can help you stay ahead of the curve.

Because in wound care, compliance isn't just about following rules- it's about saving limbs, lives, and livelihoods.

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Mike Comer is the CEO and Founder of Wound Care Advantage, a company dedicated to eliminating amputations caused by non-healing wounds. Since 2002, WCA has supported wound centers across the nation with innovative technology, expert guidance, and a commitment to clinical excellence.

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