DOJ Reaches $45 Million False Claims Act Settlement with Specialty Wound Care Providers in Record Time

On Nov. 21, the U.S. Department of Justice (DOJ) announced that Dr. Ameet Vohra and his company, Vohra Wound Physicians Management, one of the nation’s largest providers of specialty wound care for patients in nursing homes and skilled nursing facilities (SNFs), have agreed to pay $45 million to resolve allegations that they submitted false and improper claims to Medicare.

The case began in April, when the United States filed a civil lawsuit under the False Claims Act (FCA) against Vohra and related entities, formally accusing them of a nationwide scheme to defraud Medicare using a systemic program of upcoding and false documentation – repeatedly converting non-surgical or routine wound care (or care not provided at all) into high-paying surgical billings.

For a complex, nationwide FCA case, this matter settled in record time, just over seven months after the complaint was filed, suggesting that regulators may be accelerating enforcement in this space.

The Alleged Scheme

According to the complaint from the DOJ:

Vohra allegedly billed Medicare for surgical excisional debridement procedures – a type of wound-care surgery – even when the care provided did not amount to a surgical debridement, and sometimes when only routine, non-surgical wound management occurred. Additionally:

• The company reportedly used a proprietary electronic medical record (EMR)/billing software that was programmed to treat essentially every debridement as the high-paying surgical kind, regardless of what the physician actually did.
• That same EMR system allegedly auto-populated clinical documentation, creating built-in charting templates and billing codes designed to make it appear that surgical, high-reimbursement procedures had been done, even when they had not.
• On top of that, Vohra is accused of pressuring, training, and financially incentivizing their physicians to perform debridement procedures at nearly every patient visit – maximizing volume, rather than ensuring proper medical necessity.
• Finally, the complaint alleges that they even misused billing codes for evaluation and management (E&M) services by automatically adding Modifier 25 when billing for surgeries, regardless of whether the provider actually provided a separately identifiable significant service, as Medicare requires – thereby inflating claims.

In addition to paying $45 million, Dr. Vohra and Vohra Wound Physicians Management will also enter into a five-year Corporate Integrity Agreement with the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG). Under the agreement, Vohra must implement and maintain a compliance program, conduct risk assessments, and hire an independent review organization to monitor their claims and health-information technology systems.

Wound Care Fraud is An Enforcement Priority

The Vohra settlement is not an outlier, but instead part of a larger trend. Over the past few years, federal authorities have repeatedly targeted wound-care providers, skin graft/supplement suppliers, and other entities that treat chronic wounds. As I reported on a previous Monitor Mondays podcast, in January, federal prosecutors announced that an Arizona couple had pleaded guilty for orchestrating a huge fraud scheme in which they submitted over $1.2 billion in false and fraudulent claims to Medicare and other federal insurance programs for medically unnecessary skin grafts on elderly and terminally ill patients.

In April 2023, HHS-OIG excluded Dr. Joel Aronowitz and Tower Multi-Specialty Medical Group from Medicare for 15 years – and forced them to pay nearly $24 million – for allegedly submitting improperly billed claims for skin substitute products.

A recent report by HHS-OIG provides helpful context for what might be fueling this alarming pattern. The report found that Medicare Part B spending on skin substitutes soared in 2023–2024, rising to over $10 billion in 2024, up roughly 640 percent from just two years earlier.

The aggressive enforcement and the dramatic growth in skin substitute billing make clear that wound care and skin grafts are now among the top targets for enforcement under the FCA.