By Mike Comer, CEO & Founder, Wound Care Advantage
The Department of Health and Human Services Office of Inspector General just dropped a bombshell this week that's sending shockwaves through our industry for some. For others like us the question is: “Why did it take so long?” The OIG report on "Medicare Part B Payment Trends for Skin Substitutes" isn't just another government document, it's a wake-up call that will reshape how wound care has been delivered over the past two to three years.
Here’s the reality: Medicare spending on skin substitutes exploded from $256 million in 2019 to over $10 billion in 2024. This does not take into account what 2025 will look like at the end of this year. My guess? Well over $20 billion. That’s not growth, that's a rocket ship loaded with the money that is supposed to be used for saving limbs and lives heading straight for the sun!
Outpatient hospital-based wound centers have largely stayed out of the chaos. A full course of treatment at these centers, typically lasting 10-12 weeks and healing most wounds within that time, costs Medicare on average about $4,216. If hyperbaric oxygen therapy is involved, the cost can rise to $24,824. However, spending on skin substitutes- CTPs, CAMPs, or whatever term you prefer, has skyrocketed. Especially in the mobile wound care market. This report highlights an 83% increase in just one year, with costs averaging $23,000 per visit and often exceeding over $100,000 for a single treatment. Shockingly, we still lack data on whether this huge spending increase has led to better healing outcomes for patients.
To put it in perspective: 10 treatments at a hospital wound center cost around $4,500. The same number of treatments through a mobile provider at home costs a staggering $230,000 and in many cases over $1 million- hundreds of thousands more than care provided by a highly trained team of physicians, nurses, and techs in a regulated, specialized environment. These centers ensure compliance with regulations, undergo routine inspections, and maintain comprehensive documentation to support their care. Mobile wound care is most often performed by a single provider with limited resources at the bedside.
Meanwhile, reports of exorbitant per-visit costs exceeding $250,000, rumors of kickbacks and rebates, waived co-pays, companies guaranteeing provider payments with "claw-back" insurance, and even inappropriate product use on hospice patients, paint a troubling picture. This opportunistic approach to wound care not only risks fraud, but may tarnish the reputation of our entire industry- damage that could take years to undo.
But here's what separates the survivors from the casualties- preparation. While many mobile and independent practices will scramble and eventually shutter, smart wound centers are already positioning themselves to not just survive, but thrive in this new landscape.
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.
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.
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:
What Wound Centers Need to Know:
Your protection: Bulletproof documentation, transparent billing practices, and clinical protocols that stand up to scrutiny.
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.
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:
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.
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.
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.
