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The Wound Care Reckoning: Defending Practices After Medicare’s 2026 Skin-Substitute Cut and the $4 Billion Takedown

Medicare’s 2026 skin-substitute cut and a data-driven enforcement push now expose wound-care clients to criminal referrals, payment suspensions, and revocation. Spot the billing patterns that trigger investigations, test client conduct against the four fraud theories, and rebuild a compliant billing program.

2026-12-04 12:00:00

Program Details

2026-12-04 12:00:00

Program Details

2026-12-04 12:00:00

Over 1,000+ webinars

2026-12-04 12:00:00

Course Overview

The Rate Cut Was the Warning. The Investigation Is the Real Risk

2026-12-04 12:00:00

On January 1, 2026, CMS overhauled how Medicare pays for skin substitutes, and payment dropped sharply. The federal government followed with an aggressive, data-driven enforcement push. Wound-care practices now face criminal referrals, payment suspensions, and removal from Medicare across the country.

Bill in a pattern the claims data flags, and analytics can open an investigation before anyone complains. Miss the documentation, and 2025 and 2026 claims fail ADR review and prepayment audit. Let a payment suspension escalate, and revocation under 42 C.F.R. § 424.535 brings a 10-year reenrollment bar. Leave billing red flags in place, and the qui tam pipeline can feed the government’s case. Rely on the withdrawn Local Coverage Determinations, and appeals turn on MAC-by-MAC variation.

You walk out with documentation checklists and a working map of how investigators build these cases. You also get a step-by-step framework for rebuilding a compliant billing program after a penalty. It covers the Corrective Action Plan pathway and the Anti-Kickback and commercial-payer exposures to scrub before reenrollment. That is the judgment clients pay counsel for when a suspension notice arrives.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Detection and Enforcement Priorities
Identify how claims-data analytics single out wound-care practices as targets and why DOJ has made skin-substitute spending an enforcement priority.
02
The Four Fraud Theories
Apply the four core fraud theories DOJ and OIG are using to judge where a client’s conduct turns a compliance problem into criminal exposure.
03
Red Flags and Qui Tam
Spot the claim-level billing patterns that trigger scrutiny and assess how the qui tam pipeline intersects with a government-initiated investigation.
04
What the 2026 Cut Changed
Separate what CMS changed on January 1, 2026 from what it did not, including whether the rate cut makes skin substitutes non-covered.
05
Suspension and Revocation Mechanics
Trace how a payment suspension escalates into revocation under 42 C.F.R. § 424.535 and what the 10-year reenrollment bar means for the practice.
06
Documentation and Reenrollment
Build the documentation record that withdrawn coverage rules and audit triggers now demand, and use corrective action to move a penalized practice back to reenrollment.

Program schedule

clock 12:00 pm - 1:00 pm EST

How the Government Builds a Skin-Substitute Fraud Case Against Wound-Care Practices

This session walks through how the federal government finds, investigates, and prosecutes Medicare skin-substitute fraud. Attorneys will learn how data analytics start an investigation, which legal theories drive today’s prosecutions, and which billing patterns act as red flags in claims review. Attendees leave able to recognize the evidence these cases are built on and to counsel clients on the conduct that turns a compliance problem into criminal exposure.

Rachel Hold-WeissRachel Hold-Weiss
Christopher T. GrohmanChristopher T. Grohman
clock 1:10 pm - 2:10 pm EST

Payment Suspensions, Revocations, and Rebuilding Wound-Care Billing After the 2026 Cut

This session covers what happens to wound-care practices after the 2026 cut: Medicare payment suspensions, the expanded grounds CMS can use to revoke a provider’s enrollment under 42 C.F.R. § 424.535, and the corrective-action path back to reenrollment. Attorneys will learn how withdrawn Local Coverage Determinations, the collapse of old billing habits, and AI-driven prepayment review combine into cascading liability. Attendees leave knowing the documentation requirements, how suspensions and revocations work, and the steps needed to rebuild a compliant billing program.

Rachel Hold-WeissRachel Hold-Weiss
Christopher T. GrohmanChristopher T. Grohman
Rachel Hold-Weiss

Rachel Hold-Weiss

Benesch, Friedlander, Coplan & Aronoff LLP

Christopher T. Grohman

Christopher T. Grohman

Benesch, Friedlander, Coplan & Aronoff LLP

Rachel Hold-Weiss

Rachel Hold-Weiss

Benesch, Friedlander, Coplan & Aronoff LLP

Rachel Hold-Weiss is a partner in the Healthcare Practice Group of Benesch, Friedlander, Coplan & Aronoff LLP in New York. She represents healthcare providers through Medicare audits and appeals, federal and state investigations, and fraud and abuse matters, including reviews by the HHS Office of Inspector General, the New York State Office of the Medicaid Inspector General, and CMS Medicare Administrative Contractors. A licensed physician assistant since 1996, she brings clinical training to a regulatory, transactional, and litigation practice centered on post-acute and long-term care providers.

Education & Credentials

Ms. Hold-Weiss received her J.D. from Fordham University School of Law and her B.S., cum laude, in Physician Assistant studies from Touro College. Before practicing law, she worked as a physician assistant in inpatient and outpatient clinical settings, and she has been licensed as a physician assistant in New York since 1996. She is admitted to practice in New York and the District of Columbia and before the U.S. District Courts for the Southern and Eastern Districts of New York.

Recognition & Leadership

Ms. Hold-Weiss is listed in The Best Lawyers in America for Health Care Law (2025–2027), has been recognized by Chambers USA as a top up-and-coming health care attorney in New York, and is rated by The Legal 500 United States as a national leader in the healthcare field. She serves on the Board of Trustees of the Hospice and Palliative Care Association of New York State and on the Board of Trustees of Community Health Accreditation Partner (CHAP).

Professional Involvement

Ms. Hold-Weiss is a member of the American Health Law Association and the National Alliance for Care at Home. She speaks frequently on government audits and enforcement, with recent presentations including “What To Do When the Spotlight Finds You” (2026), “The Government is Coming, the Government is Coming!” (2024), “Home Health and Hospice in the Government Crosshairs” (2024), “TPEs, SMRCs and UPICs Oh My! – How to Successfully Manage Appeals” (2023), and “Administrative Appeals: Strategies for Success in UPIC, ALJ and MAC Appeals” (2023). She was featured on the American Health Law Association's “Speaking of Health Law” podcast episode “Audit Defense: What Health Care Providers and Attorneys Need to Know” (2026), and Axios quoted her in 2026 on Medicare's cuts to bioengineered wound care.

Experience

Ms. Hold-Weiss has represented many providers through the Medicare audit and appeals process and regularly defends physicians and healthcare organizations in fraud and abuse matters involving anti-kickback, self-referral, false claims, corporate practice of medicine, and fee-splitting issues. She also advises on Medicare and Medicaid survey and reimbursement issues, designs and implements compliance programs, and conducts compliance audits.

Her clients include nonprofit and for-profit hospices and palliative care programs, home health agencies, skilled nursing and assisted living facilities, physicians, physician practices, and physician practice management companies. She represents investors, owners, and operators in regulatory and corporate due diligence, restructurings, sales, and acquisitions, and advises on certificate of need, facility and professional licensure, and healthcare privacy and security. Before joining Benesch in 2023, she was a partner at Arent Fox, and she previously served as Associate General Counsel and Corporate Compliance Officer for the Personal-Touch Home Care companies, a home care company with operations in 11 states.
Christopher T. Grohman

Christopher T. Grohman

Benesch, Friedlander, Coplan & Aronoff LLP

Christopher T. Grohman is a partner in the Chicago office of Benesch, Friedlander, Coplan & Aronoff LLP, where he defends healthcare providers and other companies in False Claims Act investigations, government audits, Medicare recoupment actions, and criminal healthcare fraud prosecutions. He has first-chaired hundreds of Medicare administrative law judge appeals, with a focus on wound care, home healthcare, and hospice. He previously served as an Assistant United States Attorney for the Northern District of Illinois.

Education & Credentials

Mr. Grohman earned his J.D. from Harvard Law School in 2006 and his B.S. in Economics, summa cum laude, with a concentration in Finance and a minor in Mathematics, from the Wharton School of the University of Pennsylvania in 2003. He clerked for the Hon. Algenon L. Marbley of the U.S. District Court for the Southern District of Ohio (2006–2007) and for the Hon. Ann Claire Williams (ret.) of the U.S. Court of Appeals for the Seventh Circuit (2009–2010). He is admitted to practice in Illinois and California, before the U.S. Courts of Appeals for the Sixth and Seventh Circuits, and in the U.S. District Courts for the Northern District of Illinois, the Southern District of Ohio, and the Eastern and Western Districts of Wisconsin.

Recognition & Leadership

Mr. Grohman is ranked by Chambers USA in Litigation: White-Collar Crime & Government Investigations (Band 4, 2026) and was named to the Legal 500 City Elite in 2026. He has been recognized as an Illinois Super Lawyer in Criminal Defense: White Collar (2023–2025), as a Leading Lawyer (2019–2021), and by Crain's Chicago Business as one of its Notable Leaders in Accounting, Consulting & Law (2024). During his government service, the United States Postal Inspection Service named him Prosecutor of the Year in 2014, and he received a 2013 award from Chicago Crime Stoppers.

Professional Involvement

Mr. Grohman teaches Federal Criminal Law as an adjunct professor at the University of Illinois Chicago School of Law and previously taught legal drafting as an adjunct professor at DePaul University's law school. He has also served as an instructor at the Federal Law Enforcement Training Center and the National Advocacy Center. He is a member of the American Bar Association, where he has served as Vice-Chair of the Young Lawyers Division's Criminal Justice Committee, as well as the Federal Bar Association, the Chicago Bar Association, the Seventh Circuit Bar Association, and the Just the Beginning Foundation. His recent speaking engagements include “Government Investigations in the Long-Term Care Space” (2023) and “Representing Whistleblowers During Internal Investigations” (2026).

Experience

Mr. Grohman's healthcare practice centers on Medicare compliance and fraud defense. At Benesch, he led the team that secured the dismissal of all criminal charges against the owner of CarePlus Hospice Services, Inc. in a California prosecution alleging more than $7 million in fraudulent hospice billing, and he has handled dozens of federal and state False Claims Act investigations involving Medicare overbilling and other allegations. Earlier in his career, he defended a podiatrist and related company accused of more than $70 million in Medicare fraud tied to a computerized medical records system, obtained probation for an internal medicine physician accused of fraudulently billing Medicare and private insurers more than $3 million, defended a nursing home group in a federal False Claims Act investigation of "worthless care" allegations, and obtained a restraining order preventing the State of Illinois from withholding Medicaid funds from the state's largest Medicaid provider. He was also lead appellate counsel in United States v. Borassi, a leading Seventh Circuit decision on the safe harbor under the anti-kickback provision of the Medicare fraud statute.

Beyond healthcare, Mr. Grohman has defended matters brought by DOJ, the SEC, the CFPB, and the CFTC, and has conducted internal investigations for Fortune 500 companies involving accounting fraud, executive embezzlement, theft of trade secrets, and FCPA issues. An experienced trial lawyer, he tried seven jury cases as a federal prosecutor and more than a dozen additional trials in private practice, including an eight-day federal jury trial that ended in a complete acquittal on all charges.
Rachel Hold-Weiss

Rachel Hold-Weiss

Benesch, Friedlander, Coplan & Aronoff LLP

Rachel Hold-Weiss is a partner in the Healthcare Practice Group of Benesch, Friedlander, Coplan & Aronoff LLP in New York. She represents healthcare providers through Medicare audits and appeals, federal and state investigations, and fraud and abuse matters, including reviews by the HHS Office of Inspector General, the New York State Office of the Medicaid Inspector General, and CMS Medicare Administrative Contractors. A licensed physician assistant since 1996, she brings clinical training to a regulatory, transactional, and litigation practice centered on post-acute and long-term care providers.

Education & Credentials

Ms. Hold-Weiss received her J.D. from Fordham University School of Law and her B.S., cum laude, in Physician Assistant studies from Touro College. Before practicing law, she worked as a physician assistant in inpatient and outpatient clinical settings, and she has been licensed as a physician assistant in New York since 1996. She is admitted to practice in New York and the District of Columbia and before the U.S. District Courts for the Southern and Eastern Districts of New York.

Recognition & Leadership

Ms. Hold-Weiss is listed in The Best Lawyers in America for Health Care Law (2025–2027), has been recognized by Chambers USA as a top up-and-coming health care attorney in New York, and is rated by The Legal 500 United States as a national leader in the healthcare field. She serves on the Board of Trustees of the Hospice and Palliative Care Association of New York State and on the Board of Trustees of Community Health Accreditation Partner (CHAP).

Professional Involvement

Ms. Hold-Weiss is a member of the American Health Law Association and the National Alliance for Care at Home. She speaks frequently on government audits and enforcement, with recent presentations including “What To Do When the Spotlight Finds You” (2026), “The Government is Coming, the Government is Coming!” (2024), “Home Health and Hospice in the Government Crosshairs” (2024), “TPEs, SMRCs and UPICs Oh My! – How to Successfully Manage Appeals” (2023), and “Administrative Appeals: Strategies for Success in UPIC, ALJ and MAC Appeals” (2023). She was featured on the American Health Law Association's “Speaking of Health Law” podcast episode “Audit Defense: What Health Care Providers and Attorneys Need to Know” (2026), and Axios quoted her in 2026 on Medicare's cuts to bioengineered wound care.

Experience

Ms. Hold-Weiss has represented many providers through the Medicare audit and appeals process and regularly defends physicians and healthcare organizations in fraud and abuse matters involving anti-kickback, self-referral, false claims, corporate practice of medicine, and fee-splitting issues. She also advises on Medicare and Medicaid survey and reimbursement issues, designs and implements compliance programs, and conducts compliance audits.

Her clients include nonprofit and for-profit hospices and palliative care programs, home health agencies, skilled nursing and assisted living facilities, physicians, physician practices, and physician practice management companies. She represents investors, owners, and operators in regulatory and corporate due diligence, restructurings, sales, and acquisitions, and advises on certificate of need, facility and professional licensure, and healthcare privacy and security. Before joining Benesch in 2023, she was a partner at Arent Fox, and she previously served as Associate General Counsel and Corporate Compliance Officer for the Personal-Touch Home Care companies, a home care company with operations in 11 states.
Christopher T. Grohman

Christopher T. Grohman

Benesch, Friedlander, Coplan & Aronoff LLP

Christopher T. Grohman is a partner in the Chicago office of Benesch, Friedlander, Coplan & Aronoff LLP, where he defends healthcare providers and other companies in False Claims Act investigations, government audits, Medicare recoupment actions, and criminal healthcare fraud prosecutions. He has first-chaired hundreds of Medicare administrative law judge appeals, with a focus on wound care, home healthcare, and hospice. He previously served as an Assistant United States Attorney for the Northern District of Illinois.

Education & Credentials

Mr. Grohman earned his J.D. from Harvard Law School in 2006 and his B.S. in Economics, summa cum laude, with a concentration in Finance and a minor in Mathematics, from the Wharton School of the University of Pennsylvania in 2003. He clerked for the Hon. Algenon L. Marbley of the U.S. District Court for the Southern District of Ohio (2006–2007) and for the Hon. Ann Claire Williams (ret.) of the U.S. Court of Appeals for the Seventh Circuit (2009–2010). He is admitted to practice in Illinois and California, before the U.S. Courts of Appeals for the Sixth and Seventh Circuits, and in the U.S. District Courts for the Northern District of Illinois, the Southern District of Ohio, and the Eastern and Western Districts of Wisconsin.

Recognition & Leadership

Mr. Grohman is ranked by Chambers USA in Litigation: White-Collar Crime & Government Investigations (Band 4, 2026) and was named to the Legal 500 City Elite in 2026. He has been recognized as an Illinois Super Lawyer in Criminal Defense: White Collar (2023–2025), as a Leading Lawyer (2019–2021), and by Crain's Chicago Business as one of its Notable Leaders in Accounting, Consulting & Law (2024). During his government service, the United States Postal Inspection Service named him Prosecutor of the Year in 2014, and he received a 2013 award from Chicago Crime Stoppers.

Professional Involvement

Mr. Grohman teaches Federal Criminal Law as an adjunct professor at the University of Illinois Chicago School of Law and previously taught legal drafting as an adjunct professor at DePaul University's law school. He has also served as an instructor at the Federal Law Enforcement Training Center and the National Advocacy Center. He is a member of the American Bar Association, where he has served as Vice-Chair of the Young Lawyers Division's Criminal Justice Committee, as well as the Federal Bar Association, the Chicago Bar Association, the Seventh Circuit Bar Association, and the Just the Beginning Foundation. His recent speaking engagements include “Government Investigations in the Long-Term Care Space” (2023) and “Representing Whistleblowers During Internal Investigations” (2026).

Experience

Mr. Grohman's healthcare practice centers on Medicare compliance and fraud defense. At Benesch, he led the team that secured the dismissal of all criminal charges against the owner of CarePlus Hospice Services, Inc. in a California prosecution alleging more than $7 million in fraudulent hospice billing, and he has handled dozens of federal and state False Claims Act investigations involving Medicare overbilling and other allegations. Earlier in his career, he defended a podiatrist and related company accused of more than $70 million in Medicare fraud tied to a computerized medical records system, obtained probation for an internal medicine physician accused of fraudulently billing Medicare and private insurers more than $3 million, defended a nursing home group in a federal False Claims Act investigation of "worthless care" allegations, and obtained a restraining order preventing the State of Illinois from withholding Medicaid funds from the state's largest Medicaid provider. He was also lead appellate counsel in United States v. Borassi, a leading Seventh Circuit decision on the safe harbor under the anti-kickback provision of the Medicare fraud statute.

Beyond healthcare, Mr. Grohman has defended matters brought by DOJ, the SEC, the CFPB, and the CFTC, and has conducted internal investigations for Fortune 500 companies involving accounting fraud, executive embezzlement, theft of trade secrets, and FCPA issues. An experienced trial lawyer, he tried seven jury cases as a federal prosecutor and more than a dozen additional trials in private practice, including an eight-day federal jury trial that ended in a complete acquittal on all charges.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Pending
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs