Skin Substitute and Wound Care Fraud Investigations: What Providers Need to Know in 2026

Federal investigators reviewing skin substitute billing during a Medicare fraud audit and enforcement investigation

Skin substitutes and advanced wound care have quietly become one of the most aggressive enforcement areas in federal health care fraud. What began as civil audits and payment reviews has increasingly evolved into subpoenas, False Claims Act cases, and criminal investigations. I expect this trend to accelerate in 2026. In my practice, I am seeing […]

Non-jail sentence following prosecution for violation of AKS

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I regularly represent health care providers, marketers, and health care organizations accused of or under investigation for health care fraud and violations of the anti-kickback statute.  Recently, I represented the owner of a pharmacy.  The owner was charged with engaging in a conspiracy to pay kickbacks in exchange for referrals, in addition to other crimes.  The […]

A win for the defense in False Claims Act actions

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In United States ex rel, Sheldon v. Allergan Sales, LLC, the relator claimed that defendant drug manufacturer had engaged in an allegedly fraudulent price reporting scheme under the Medicaid Drug Rebate Statute.  Under the Rebate statute, drug manufacturers seeking to have drugs covered by Medicaid must enter into rebate agreements by which they provide quarterly […]

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