Notes on Financial and Legal Implications of Measurement Inconsistencies and CTPs

• CTPs/skin substitutes (US wound care): Measurement inaccuracies can trigger denials and audits that may unwind the entire episode of care, with retrospective recoupments; OIG scrutiny remains ongoing.
• Practice-wide risk: Documentation integrity and measurement consistency affect all practice sizes; audit exposure applies equally to small practices and large health systems.
• Digital measurement tools (e.g., Swift Medical): Reported ~95% accuracy and 99% intra-operator consistency; support more consistent documentation and medical necessity narratives but do not replace clinical judgment.

Please note: This content is a direct transcript, capturing the authentic conversation without edits. Some language may reflect the flow of live discussion rather than polished text. 

Mr. Nelson is the VP Sales & Marketing for Swift Medical and Founder of the WoundCareFund & Below the Knee.

Now what happens if we get it wrong, right? Financial/legal implications, and there's quite a few. 
 
So let's zoom out from the wound and really look at the holistic practice level. So denials don't just affect one application. They unwind the entire episode. So if you're having somebody come and look and they're really just talking about the accuracy issue, but they didn't determine that the accuracy was consistent in the method of application. Now, if they're going to be doing that next level round of an audit or a clawback, they're looking at the entire episode of care. So that's where I think having these things really understand the potential implications. So recoupments can then be retrospective and broad. We've seen the OIG scrutiny. Again, the spotlight is not going to be off CTPs anytime soon, even though the reimbursement, the fee schedule's changed. So these are areas to really be cognizant.
 
We think about scale. You may be in a sole provider, you may be in a small practice group, but look at some of the larger private equity–backed hospital affiliated wound care groups that have much more involved, all these pieces. You're a smaller version of that. You're doing the same care, seeing the same patients and providing the same level of treatment. But just know that the documentation integrity, if it's important for them, it's important for you. The same risk. You have the same risk as they do as well. So you can look at some of these larger organizations and these digital tools are scalable. So if they're employable by these large organizations, they can easily scale to a sole provider. So all these tools that are available for the bigs, they're available for everybody. And it's really going to help just simply provide a more accurate and consistent component to the overall medical necessity story that you're creating in your practice.
 
So in 2026 wound care, precision isn't optional, it's protective. So practices that treat measurement as infrastructure and not just a checkbox are really the ones who are going to not only survive, but thrive. We're continuing to be in a mix in the industry in which we're in, in wound care, but it's significant opportunity. And it's about really kind of getting that consistent pattern to defend the ... It's not that all providers need to spend all of their days thinking defensively about what could happen, but by bringing, we know that this is an Achilles heel. Accuracy of measurements and consistency of practice is an area of exposure. 
 
And I think getting some objective digital imaging tools, I'm happy to speak to you about Swift [Skin and Wound]. There's other tools available, but there's a lot of tools that are available that can give you incredible accuracy. We'll pick on Swift for just a few moments, but 95% accuracy, 99% intraoperator consistency really provides a very mobile deployable solution with spectral imaging to give you the clinician tools to allow you to make better clinical decisions.

These tools are not diagnostics. No one's going to cross that line. They're not replacing you. But it really gives you all the opportunity to have more accuracy and consistency as you're building those medical necessity and just remove some of the variability that is subject to interpretation.