Defining Fraud, Waste and Abuse in Medicare: CMS Clarifies Standards for Skin Substitute Reform

• The Centers for Medicare & Medicaid Services (CMS) defines fraud as intentional misrepresentation or deception for improper Medicare benefit/payment; waste as over-use or misuse of resources without intent; and abuse as practices inconsistent with sound fiscal, business, or medical practices.¹
• CMS identifies mounting concerns of fraud, waste, and abuse in the wound-care skin substitute market, noting Medicare Part B spending rose to over $10 billion annually in 2024.²
• In response, CMS is reforming payment policy for skin substitutes (effective Jan 1 2026) and launching the voluntary Wasteful and Inappropriate Service Reduction Model (WISeR) to reduce misuse of high-risk services.³

Healthcare providers and wound care stakeholders should note that CMS...