July 9, 2026
Let’s Work Together on Wound Care
By Jeanine Maguire, PhD, MPT, CWS, FCPP
Wound care in post-acute and long-term care (PALTC) is at a crossroads. For medical directors, administrators, and clinical leaders, pressures are converging simultaneously across five dimensions:
- Education: No unified training standard exists across wound types or disciplines, leaving clinical teams to piece together knowledge from fragmented, siloed sources.
- Regulation: F-tags, maximum allowable cost (MAC) policies, and assessment instruments segment patients by wound type.
- Compliance and fraud risk: The 2025 Department of Justice (DOJ) health-care fraud takedown disproportionately implicated wound care providers, with Medicare spending on skin substitutes rising over 600% in two years.
- Litigation: Wound care remains among the most litigated areas in PALTC, driven largely by miscommunication and unmanaged family expectations.
- Accountability: Contracting with a mobile wound group does not transfer the medical director’s regulatory, quality, or liability obligations.
The Education Gap: A Foundation Built on Fragments
Despite the prevalence and complexity of chronic wounds in older adults, wound care education across all clinical disciplines remains critically fragmented. Medical schools, nursing programs, pharmacy curricula, and physical and occupational therapy curricula devote the majority of wound-related instruction to acute wounds, surgical wounds, and burns. Chronic wounds—pressure injuries, diabetic foot ulcers (DFUs), venous leg ulcers (VLUs), skin tears, and others—lack a unified specialty designation and, consequently, have no common educational standard that applies across wound types and clinical roles.1 Organizations such as the Wound Healing Society (WHS) and the National Pressure Injury Advisory Panel (NPIAP) have produced rigorous, evidence-based guidelines for specific wound categories.2,3
The Regulatory Maze: Well-Intentioned, Yet Fragmented
Regulatory frameworks, though designed to protect patients and ensure quality, have paradoxically deepened the fragmentation. Requirements vary by state, by Medicare Administrative Contractor, and by payer. The Centers for Medicare & Medicaid Services (CMS) Outcome and Assessment Information Set (OASIS) instruments in home health and the Minimum Data Set (MDS) in skilled nursing facilities each segment wound types and patient conditions independently. Medical directors and care teams are rightly instructed not to conflate skin failure with pressure injuries—yet no ICD-10-CM code for skin failure currently exists, leaving clinicians without a specific code for documentation. PAWSIC is addressing this by collaborating with organizations and submitting a proposal for a code to the CDC ICD-10_CM Committee.4
Consider the F-tag architecture alone: F686 addresses pressure injuries; F684 encompasses diabetic foot ulcers and venous leg ulcers; F880 brings infection control and now mandates enhanced barrier precautions for chronic wounds. Yet skin tears—the most prevalent wound type in the older adult population and a frequent precursor to chronic wounds—have no dedicated F-tag.5 F880’s addition of advanced barrier precautions is a welcome signal that regulatory bodies recognize infection risk in chronic wounds, yet the regulation stops short of providing guidance on internal or external wound infection risk mitigation.
Meanwhile, acute care penalties, such as the Hospital Readmissions Reduction Program (HRRP) 30-day readmission penalty, reinforce the same message from the acute side. Skin and wound-related conditions, including surgical site infections—a leading cause of readmission—frequently occur in the same patient populations who carry risk for or already have chronic wounds.6
The Medical Director’s Accountability
Federal F-tag requirements explicitly hold medical directors responsible for oversight of the clinical programs operating within their facilities, including wound care. Many organizations have elected to contract with external mobile wound groups, which can offer expertise and continuity. However, the engagement of an external consultant does not transfer the medical director’s regulatory, quality, and liability obligations. The F-tags, the quality measures, the infection and hospitalization rates, and the litigation risk remain the facility’s and medical director’s responsibility.
When selecting a wound consultant or mobile wound group, medical directors should ask: Are their clinicians wound-certified? Are they accredited by a recognized body? Do they practice within federal regulatory frameworks and understand the specific F-tags governing your facility? Will they select treatments within your formulary? Will their documentation integrate with your electronic medical record? And are they available 24/7 when wound events, complications, and deterioration can occur?
Federal Scrutiny: A Clarion Call, Not a Condemnation
The wound care field has come under significant scrutiny from the DOJ and the Department of Health and Human Services Office of Inspector General (HHS-OIG). In 2025, DOJ announced what it characterized as the largest health-care fraud takedown in history, with more than 300 defendants charged in schemes involving over $14 billion in intended losses—a striking number of which involved wound care providers, skin substitute products, and cellular and tissue-based products.7,8 Medicare Part B spending on skin substitutes increased by more than 600% between 2022 and 2024, reaching nearly $3 billion per quarter, prompting urgent concern from HHS-OIG about fraud, waste, and abuse.9 High-profile settlements have included a $309 million resolution involving false claims for amniotic wound allografts and a $45 million settlement with one of the nation’s largest mobile wound care companies for allegedly billing Medicare for surgical debridement procedures that were medically unnecessary or not performed.8
While the clinicians and organizations implicated in these actions represent a fraction of the wound care community, these cases are a call to action for medical directors to understand the landscape well enough to meaningfully vet their wound care consultants, and mobile wound groups must demonstrate alignment with best practices, documentation integrity, and compliance proactively.
Litigation Risk: The Human Cost of Unmanaged Expectations
Wound care is among the most litigated areas in PALTC. Wounds are viscerally distressing to observe. Families confronting a loved one’s pressure injury, deteriorating diabetic foot ulcer, or an infected surgical wound are often frightened and confused. The general public does not understand the multifactorial etiology of chronic wounds, and when the care team fails to communicate clearly about causation, prognosis, and the interventions being employed, grief and fear can quickly become blame and litigation.
The Wound Is Not the Problem. It’s the Signal.
Chronic wounds are often the physical manifestation of poorly managed chronic disease. The patient with a non-healing wound is likely to have a history of cardiovascular or vascular disease, metabolic disease or diabetes, neurological disease, mobility impairment, nutritional deficits, and mental health comorbidities.1,10 These predisposing conditions compound with advanced age and polypharmacy. Medications may directly impair wound healing by affecting perfusion, immune function, and tissue regeneration.11
Addressing the wound requires the medical director, the nursing staff, the wound specialist, the physical and occupational therapists, the registered dietitian, the pharmacist, and in many cases the podiatrist, vascular specialist, mental health professionals, and in some cases, the hospice team working collaboratively. No single discipline possesses the full skill set patients require.10
A Path Forward: Inventory, Integration, and Accountability
PAWSIC proposes a practical, two-step foundation as a path forward. First, take inventory of your program. Assess the employed talent within your organization to determine who manages chronic disease and wounds. Investigate what wound therapies the facility formulary or the resident’s medical plan support and ensure that evidence-based (i.e., age-friendly) mobility, nutritional, and medication management programs are in place.
Second, ensure that your wound specialist—whether employed or contracted—can serve your population within the context of your program, your regulatory obligations, and your formulary. To support this evaluation, PAWSIC has updated its Wound Provider Checklist. The 2026 PAWSIC Mobile Wound Groups Checklist has been revised and segmented for different care settings, because facilities and other health-care settings have unique considerations. It is designed to move wound program evaluation from cursory credentialing to meaningful, setting-specific vetting.
Equally important is placing the patient and family at the center of the care team to understand what matters most to the resident. PAWSIC will also publish a Patient/Family Wound Guide, a plainly written resource designed to support clinician-family conversations, explain wound etiology and the care plan, and manage expectations throughout the healing process. Informed families are engaged partners, not adversaries. This simple step can measurably reduce the distress that underlies much of the litigation this field endures.
Both the Mobile Wound Groups Checklist and the Patient/Family Wound Guide will be available on the PAWSIC website.
Conclusion: From Fragmentation to a Team-Based Vision
The fragmentation in the wound care ecosystem in PALTC is can be corrected by shifting practice from siloed wound management to patient-centered, team-based, evidence-driven care. Medical directors have the opportunity to integrate the post-acute team and standardize evidence-based practices within their facilities. PAWSIC is available to collaborate with PALTmed members, medical directors, and the broader PALTC community to help advance improved wound care in PALTC.
Jeanine Maguire
President, PAWSIC.org
References
1. Frykberg, R. G., & Banks, J. (2015). Challenges in the treatment of chronic wounds. Advances in Wound Care, 4(9), 560–582. https://doi.org/10.1089/wound.2015.0635
2. National Pressure Injury Advisory Panel. (2019). Prevention and treatment of pressure injuries/ulcers: Clinical practice guideline (3rd ed.). NPIAP. https://npiap.com/page/ClinicalGuidelines
3. Wound Healing Society. (2023). Wound healing guidelines. https://www.woundheal.org/guidelines
4. Centers for Medicare & Medicaid Services. (2024). ICD-10-CM official guidelines for coding and reporting FY 2025. U.S. Department of Health and Human Services. https://www.cms.gov/files/document/fy-2025-icd-10-cm-coding-guidelines.pdf
5. LeBlanc, K., Baranoski, S., Christensen, D., Langemo, D., Sammon, M. A., & Sylvestre, J. (2018). The art of dressing selection: A consensus statement on skin tears and wound care. Advances in Skin & Wound Care, 31(4), 1–20. https://doi.org/10.1097/01.ASW.0000530099.06658.fe
6. Berríos-Torres, S. I., Umscheid, C. A., Bratzler, D. W., Leas, B., Stone, E. C., Kelz, R. R., Reinke, C. E., Morgan, S., Solomkin, J. S., Mazuski, J. E., Dellinger, E. P., Itani, K. M. F., Berbari, E. F., Segreti, J., Parvizi, J., Blanchard, J., Allen, G., Kluytmans, J. A. J. W., Donlan, R., & Schecter, W. P. (2017). Centers for Disease Control and Prevention guideline for the prevention of surgical site infection, 2017. JAMA Surgery, 152(8), 784–791. https://doi.org/10.1001/jamasurg.2017.0904
7. Tarras Defense. (2026, January 28). Wound care fraud investigations: What healthcare providers need to know. https://tarrasdefense.com/wound-care-fraud-investigations-what-healthcare-providers-need-to-know/
8. Arnold & Porter. (2026, January 14). Cracking down on alleged wound care fraud: A new era of DOJ and HHS enforcement. FCA Qui Notes. https://www.arnoldporter.com/en/perspectives/blogs/fca-qui-notes/posts/2026/01/doj-and-hhs-cracking-down-on-alleged-wound-care-fraud
9. HHS Office of Inspector General. (2024). Medicare Part B payment trends for skin substitutes raise major concerns about fraud, waste, and abuse (Report No. OEI-BL-24-00420). U.S. Department of Health and Human Services. https://oig.hhs.gov/reports/all/2025/medicare-part-b-payment-trends-for-skin-substitutes-raise-major-concerns-about-fraud-waste-and-abuse/
10. Sen, C. K., Roy, S., & Gordillo, G. (2019). Human skin wounds: A major and snowballing threat to public health and the economy. Wound Repair and Regeneration, 17(6), 763–771. https://doi.org/10.1111/j.1524-475X.2009.00543.x
11. Sgonc, R., & Gruber, J. (2013). Age-related aspects of cutaneous wound healing: A mini-review. Gerontology, 59(2), 159–164. https://doi.org/10.1159/000342344