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08/12/2025
RESPONSES/COMMENTS (WOUND CARE)
From: Joseph Borreggine, DPM
Is anyone afraid of how this is going to affect the delivery of healthcare, especially those who need wound care, such as the diabetic and venous ulcer population? Funny how dermatology is exempt, even though they create wounds with their MOHs procedures. Of course, emergency rooms and hospitals probably need to be exempt since they’re not seeing chronic wounds.
Nothing from the APMA. This is a serious situation for our profession and for wound care in general. Delay of care and treatment is what this is looking like to me. The recently proposed LCD changes that have been delayed, I guess, were not going to suffice. So, what was next? A “voluntary” program for pre-payment audits and pre-authorization, all controlled by AI. I think just everybody is like “whatever”, especially if this does not affect your CMS MAC and/or jurisdiction. But, this is moving quickly. The notice was dropped last month from CMS and will be implemented on Jan 1, 2026. This is very unusual indeed since the government never moves this quickly. Why so fast? Has anyone posted a comment on regulations.gov?
The recent DOJ indictments showing $14.6 billion in waste, fraud, and abuse certainly should open some eyes, but I guess that did not either. If you read through those cases, you’ll see a number of doctors, companies, and wound care clinics were all involved in multiple states, but it is what it is. Whether that money will ever be recouped is another story. However, full steam ahead with a need policy on wound care will fix that. Hopefully, some recent articles PM News posted are going to create some meaningful discussion as we go forward. I think the amount of money that podiatrists can make in wound care will never be like it was over the last 10 to 15 years. I think the party is over.
Joseph Borreggine, DPM, Ft. Myers, FL
Other messages in this thread:
08/13/2025
RESPONSES/COMMENTS (WOUND CARE) - PART 1C
From: Paul Kesselman, DPM
Let me make some corrections to my friend and colleague Joseph Borregine's comments on the WISer program. This is a voluntary program which is available in only six states - New Jersey, Ohio, Oklahoma, Texas, Arizona, and Washington. It is open to any provider practitioner, including DPMs who provide a subset of specific procedures. It is based on and does not usurp specific LCDs which have jurisdiction over those procedures. It is not biased for or against any specialist.
Dr. Borreggine specifically stated that dermatologists were exempt from this program. That is false! Rather, it should have stated that post Moh's surgery grafting is not subject to the WISeR program. The reason is because...
Editor's note: Dr. Kesselman's extended-length letter can be read here.
08/13/2025
RESPONSES/COMMENTS (WOUND CARE) - PART 1B
From: Aaron Ben Pearl, DPM
Regarding the question as to why CMS has acted so quickly with wound regulations, make no mistake, when The New York Times publishes an article that listed podiatry among the abusers, that got people’s attention. There’s a reason that the phrase “pigs get fat and hogs get slaughtered” applies here. The phrase “Drinking the Kool-Aid" does not as that would imply that those who abused, did not know, and if they truly believe that, they are only fooling themselves.
Aaron Ben Pearl, DPM, Arlington, VA
08/13/2025
RESPONSES/COMMENTS (WOUND CARE) - PART 1A
From: Steven J. Merckx, DPM
In his recent post about his concerns around the WISeR model, Dr. Borreggine notes, “Nothing from the APMA.” I’d like to correct this inaccuracy. Not only has APMA shared its concerns in a July 20 comment letter to CMS, but there have been multiple communications from APMA to members about the WISeR model through Weekly Focus emails, news articles on the home page of the APMA site, and a video from APMA’s health policy team.
In the comment letter sent to CMS in July, APMA raised the same issues around timely care for DFUs and other lower extremity wounds that Dr. Borreggine pointed out. I strongly encourage members to read their weekly email publications from APMA and check out the Latest News section on the home page of the website. There is important information in these communications about a wide variety of policy and payer issues, as well as critical calls to action. The more we work together to speak with one voice to CMS and other payers, the more traction our small profession will gain.
Steven J. Merckx, DPM, Chair, APMA Health Policy and Practice Committee
08/05/2025
RESPONSES/COMMENTS (WOUND CARE)
From: Joseph Borreggine, DPM
It looks like wound care is going to be facing much needed upgrade since it has recently been discovered that in 2019 the cost of wound care to Medicare was $250 million and as of 2024 that cost skyrocketed to $10 billion a year, which is more than what they spent in this country on cancer treatment in that same year. The number of patients during that time who received wound care only doubled, meanwhile the cost went up 40 times.
Based on this amount of money being spent by Medicare on skin substitutes, they decided to use this new program, which is considered “voluntary.” This will affect three MACs which include five jurisdictions within those MACs and will only be in six states. This program will be ongoing until 2031. Based on the results of this new voluntary policy, it may include the entire...
Editor's note: Dr. Borreggine's extended-length letter can be read here.
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