A Medicare clawback occurs when CMS determines that a previously paid claim was not properly
covered — and demands repayment from the clinician.
For practices that regularly bill for advanced wound care products — particularly skin
substitutes and allografts — the exposure can be significant. The cost of the products alone
can range from thousands to millions of dollars depending on volume and treatment types.
The most dangerous aspect is the timeline. Medicare can pursue recoupment for claims going
back several years. Revenue your practice earned and spent years ago can be demanded back
without warning.
Changes in coverage determinations, billing errors, documentation gaps, or retrospective
audits can all trigger clawback activity. In a landscape where audit scrutiny is increasing,
practices without protection are carrying substantial, invisible financial risk.