In early April 2025, the Department of Justice filed a lawsuit against one of the nation’s largest wound care providers, Vohra, and its majority owner. Vohra contracts with hundreds of nursing homes and other long-term care providers to come in and provide wound care for patients in those facilities. This case is the latest datapoint in a concerning pattern of alleged fraud involving wound care providers.
The U.S. alleges that Vohra overbilled the Medicare program in the following four ways, all with the goal of maximizing reimbursements from Medicare, a practice commonly known as “upcoding”:
1. Vohra created an EMR system (electronic medical record, a software used for tracking and billing medical services) that always bills debridement procedures, which are used to remove impediments to wound healing, such as dead tissue, as surgical procedures. In reality, debridement procedures can be either surgical or non-surgical. Predictably, the surgical procedure draws a higher reimbursement from Medicare.
2. Vohra hired medical providers with no or limited wound care expertise and, in its company training, intentionally obfuscated the difference between surgical and non-surgical debridement procedures.
3. Vohra set debridement procedures targets based solely on revenue goals, without any sort of accounting for anticipated patients’ needs, and pressured physicians to meet those revenue goals.
4. Vohra programmed its EMR to improperly apply a billing code called “Modifier 25” to certain debridement procedures. Modifier 25 is a billing code used to indicate that a separately billable service was performed during a medial encounter. Certain sorts of procedures, including wound debridement, are generally billed as a bundle, not allowing a physician to bill for a test immediately preceding a procedure separately. By improperly applying Modifier 25 here, Vohra inflated its Medicare reimbursement.
The U.S. claims that these schemes resulted in thousands of alleged false claims being submitted to the Medicare program and, as a result, millions in fraudulent gains for Vohra. The case will proceed in federal court in Miami.
The wound care industry is no stranger to fraud allegations, and experts have been sounding the alarm on the unsustainable costs associated with wound care procedures. One example shined light on a single patient in Florida who accumulated nearly $10 million in costs in one year.
Another type of wound care, the application of skin substitutes, has rapidly expanded in recent years. In 2019, it was a $1 billion industry; by 2024, it is a $7 billion industry. Skin substitutes fraud has also been prevalent, including a recent criminal conviction of an Arizona couple who, via upcoding, kickbacks, and other schemes, defrauded federal healthcare programs by over $1 billion.
And in 2018, a wound care provider specializing in hyperbaric oxygen therapy (exposing wounds to oxygen under increased atmospheric pressure) agreed to pay over $22 million to settle fraud allegations that the company was billing Medicare for medically unnecessary procedures.
As the examples above demonstrate, the wound care industry is enormous, growing, and extremely susceptible to fraud. Whistleblowers who know of fraud in the wound care industry can potentially file an FCA case of their own, and, if successful, share in 15% to 30% of the government’s recovery. The attorneys at Whistleblower Partners have extensive experience representing whistleblowers in cases involving healthcare fraud. If you would like more information or wish to speak to an attorney at Whistleblower Partners, please contact us for a confidential consultation.
