Wound care providers who travel to nursing homes, assisted living facilities, and patients' homes instead of running a fixed office are now squarely in the sights of federal fraud enforcement. The Department of Justice's November 2025 settlement with Vohra Wound Physicians and the $309 million Apex Medical settlement the same year both targeted bedside, travel-based wound care models that billed Medicare for debridement and skin substitute grafts across nursing home patients at a volume investigators said no legitimate course of treatment could produce. Both cases turned on the same three fact patterns: place-of-service coding that inflated the professional fee, patient selection driven by volume rather than medical need, and visit documentation that could not support the schedule being billed. A mobile wound care practice that has not checked its own coding and travel records against those three patterns is exposed.
The Travel-Based Model Under Federal Scrutiny
The $309 million Apex Medical settlement resolved a scheme the Department of Justice said generated more than $1.2 billion in false claims. According to the Department of Justice, Alexandra Gehrke and Jeffrey King ran wound graft marketing companies that sent medically untrained sales representatives into nursing homes and other facilities to find elderly Medicare beneficiaries with wounds of any kind, then arranged for amniotic skin substitute grafts to be applied without coordinating with the patients' treating physicians, in sizes larger than the wound required. Gehrke was sentenced to 15.5 years in prison and King to 14 years in October 2025, ahead of the civil settlement that resolved the companies' False Claims Act liability. The operational shape prosecutors described, providers moving between facilities to apply product to whichever patient was found rather than treating an existing caseload, is the same shape a legitimate travel-based wound care practice runs every day.
Place-of-Service Coding and the Facility Rate Gap
Medicare pays a lower facility rate under place-of-service code 31 when a nursing facility patient still has active Part A coverage, and a higher non-facility rate under code 32 once that Part A stay has ended. A July 2025 CMS system edit now flags claims that bill the higher-paying code 32 while a patient is inside an active Part A stay, the exact coding error a provider rotating through multiple facilities in a single day is most likely to make without a location-by-location tracking system. Investigators pair that coding check with the practice's signature log, the record of where and when each visit occurred, to test whether the travel time between facilities makes the billed schedule physically possible. Practices that split time between facility visits and a fixed office should also review our guide to physician office wound care billing and its own site-of-service audit risks.
A travel-based wound care practice does not need a whistleblower to trigger a federal review. A place-of-service code, a signature log, and a claims history are enough to start one.
The Volume-Driven Selection Pattern Investigators Look For
The Department of Justice alleged that Vohra Wound Physicians pressured, trained, and financially incentivized its physicians to perform surgical excisional debridement during as many nursing home visits as possible regardless of what an individual patient's wound required, and programmed its billing software to bill the higher-reimbursed procedure by default. HHS-OIG has an open review of Medicare Part B skin substitute claims from 2020 through 2023, examining whether providers documented the conservative treatment a local coverage determination requires, typically four weeks of standard wound care, before applying a graft. A mobile practice whose new patients receive a skin substitute graft or a surgical debridement on the first visit, without a documented trial of less-invasive care, is describing the same pattern found in both enforcement actions. Our companion guides on skin substitute product, size, and frequency findings and on the government's skin substitute FCA theories cover the documentation standard in more depth.
Why Early Legal Counsel Is Critical
It is critical that mobile wound care providers promptly retain experienced healthcare defense counsel upon receiving a subpoena, audit notice, investigative request, or other government inquiry. Early legal intervention can protect the provider's rights, ensure appropriate responses to government requests, avoid inadvertent admissions, preserve relevant defenses, and allow counsel to communicate with investigators on the provider's behalf. Delaying legal representation can significantly affect the outcome of a matter and expose the provider to unnecessary risk.
How Health Law Alliance Can Help
Health Law Alliance defends mobile and travel-based wound care practices against Medicare audits, civil investigative demands, and False Claims Act investigations that turn on place-of-service coding, patient selection, or visit documentation. We evaluate the same claims data, signature logs, and coding history a federal investigator would pull before deciding on a response strategy. If your practice has received an audit notice, a subpoena, or another government inquiry, contact us for a free, confidential consultation.
