On April 4, 2025, the U.S. Department of Justice filed a False Claims Act complaint in the Southern District of Florida against Vohra Wound Physicians Management LLC (Vohra WPM), its founder, Dr. Ameet Vohra, and VHS Holdings. Vohra WPM, one of the nation’s largest wound-care providers, services hundreds of nursing homes and skilled nursing facilities (SNFs) nationwide.
The government alleges a widespread scheme to defraud Medicare by systematically overbilling for wound-care services—particularly through the improper billing of wound debridement procedures.
This analysis summarizes the key allegations, identifies potential weaknesses in the government’s case from a defense perspective, compares similar FCA cases involving electronic medical records (EMRs), and considers the broader implications for future enforcement and healthcare providers.
Key Allegations in the Vohra FCA Complaint
The government claims Vohra’s proprietary electronic medical record (EMR) system was designed to bill all debridements as surgical excisional procedures (CPT codes 11042–11047), regardless of what was actually performed. In many cases, clinicians allegedly performed selective debridements (CPT 97597/97598) or less intensive treatments. According to the complaint, from 2015 to 2023, the EMR was configured to prevent the selection of codes for simple debridements—effectively forcing upcoding for nearly eight years.
DOJ alleges that many of the billed surgical debridements were not medically reasonable or necessary. The complaint highlights repeated procedures—sometimes dozens on the same wound—as evidence that clinical judgment was overridden by profit motives. In one case, an 89-year-old nursing-home resident received 55 surgical debridements in a single year, including weekly treatments on a healing wound. Billing continued for five more consecutive weeks thereafter. Such frequency, the government argues, suggests automatic, revenue-driven treatment, not patient-specific care.
The complaint also alleges that some procedures were billed but never performed. Citing photographic evidence, DOJ contends that wounds often showed no clinical change before and after the alleged debridement. For instance, one photo taken the day before an excisional procedure showed intact skin with no necrotic tissue; the following day’s photo showed the same skin condition—suggesting that no surgical debridement had occurred. These services were allegedly documented using templated notes unsupported by the clinical record.
Finally, the DOJ challenges Vohra’s use of Modifier 25, which allows a separate evaluation and management (E/M) charge on the same day as a procedure—but only if the E/M service is significant and distinct. The complaint alleges that Vohra’s EMR was programmed to automatically append Modifier 25 and generate a separate E/M claim whenever a debridement was performed and another wound noted, regardless of whether a separate evaluation occurred. Because surgical debridements are paid as global procedures—including associated exam work—this automation resulted in improper double billing.
The government attributes the scheme to a combination of company-wide tactics, such as Vohra’s custom-built electronic medical record (EMR) system that strictly controlled physician documentation and coding. According to the complaint, the EMR: restricted free-text entries, auto-populated templated notes with misleading detail, calculated debrided tissue volume based on the presence—not removal—of devitalized tissue; and allowed only surgical excisional debridement billing (CPT 11042–11047) during 2015–2023.
If a wound showed any necrotic tissue, the system forced documentation of a debridement unless a narrow exception was selected. It then auto filled the record with prewritten language and an assumed volume of tissue removed, regardless of clinical reality. Physicians had no option to bill for lower-level selective debridements (CPT 97597/97598). The government claims this was an intentional design choice made after a 2015 internal pilot revealed that Medicare Part B would not separately reimburse for selective debridements in SNF settings due to consolidated billing rules.
The DOJ also alleges that Vohra employed many physicians without prior wound-care experience and trained them using protocols that blurred the distinction between surgical and nonsurgical debridements. The company purportedly failed to explain key Medicare billing rules and did not disclose that the EMR automatically coded all debridements as surgical. As a result, physicians unknowingly followed company protocols that misrepresented the services performed.
The complaint further alleges that Vohra set aggressive performance benchmarks—such as a “Reference Index” and “Revenue Per Encounter (RPE)”—to drive debridement volume. Physicians were reportedly evaluated and, in some cases, threatened with termination if they failed to meet quotas. These targets, the government argues, created strong incentives to perform—or at least document—a debridement at nearly every patient encounter, contributing to medically unnecessary or fabricated billing.
In sum, DOJ characterizes the conduct as a top-down, systemic scheme led by company leadership. Through its custom EMR and performance-driven policies, Vohra allegedly orchestrated widespread overbilling of Medicare for complex surgical procedures—many of which were either unwarranted or not performed as claimed.
Potential Defense Angles and Government Hurdles
Despite the complaint’s detailed allegations, the government’s case may encounter significant hurdles—chief among them, proving scienter.
Under the False Claims Act, the government must establish that the defendants acted “knowingly,” meaning with actual knowledge, deliberate ignorance, or reckless disregard of the truth. This is no small task. The defense will likely argue that the disputed conduct stemmed from good-faith efforts to navigate complex and often ambiguous Medicare billing rules—not from fraudulent intent.
For example, the EMR’s standardized coding features may be framed as an efficiency measure, designed to streamline documentation for clinicians in high-volume settings, not as a tool to inflate billing. Likewise, the defense may argue that the omission of selective debridement codes was based on a reasonable, albeit mistaken, interpretation of Medicare’s consolidated billing policies for SNFs—not a deliberate attempt to overbill.
Further, Dr. Vohra and his team might contend that they genuinely believed frequent debridements were clinically appropriate in long-term care contexts, especially for chronic wounds. If so, even systematic overuse may reflect negligent medical judgment rather than intentional fraud.
Another likely defense theme is the inherent subjectivity of medical necessity. Retrospective judgments about whether a procedure was “necessary” often vary—even among experienced clinicians. What one wound-care specialist might call excessive, another might view as a prudent, preventive measure.
The defense will argue that decisions about debridement frequency require clinical judgment based on a range of factors, including wound progression, infection risk, and patient comorbidities. Many patients in skilled nursing facilities were elderly, immobile, or had vascular complications—conditions that may reasonably justify frequent intervention to prevent deterioration.
Importantly, courts have recognized that a mere difference of medical opinion is not fraud. In United States v. AseraCare, Inc., the Eleventh Circuit held that a claim cannot be false under the FCA simply because the government’s expert disagrees with the treating physician’s medical judgment, absent an objective falsehood. Here, Vohra’s defense will likely assert that the government is impermissibly second-guessing clinical decisions with the benefit of hindsight.
The government’s emphasis on Vohra’s EMR system—particularly its automated features—may prove a double-edged sword. The defense will argue that automation, templates, and drop-down menus are not only industry standard but often essential for clinical efficiency and documentation consistency. The use of prepopulated language, limited coding options, and default selections is common in healthcare software and, standing alone, is not indicative of fraud.
Vohra’s counsel is likely to assert that the EMR’s design was aimed at standardizing care and minimizing billing errors, not at misrepresenting services. That the EMR restricted documentation or routed physicians toward certain codes may be framed as a good-faith effort to align with Medicare’s complex rules—especially in the SNF context, where billing is constrained by consolidated payment systems.
The government, however, points to a more damning fact: the EMR’s removal of the option to bill for selective debridements shortly after learning that such codes wouldn’t be reimbursed under Medicare Part B in SNFs. The defense will need to confront this chronology directly. Additionally, the defense may argue that any misuse of EMR features by individual clinicians was contrary to company policy, not the result of institutional intent to defraud.
Ultimately, the defense will aim to decouple automated functionality from fraudulent intent—emphasizing that while flawed, the EMR system was a tool for operational consistency, not a mechanism for deceit.
Medicare’s billing rules—particularly those involving global surgery packages and the use of Modifier 25—are notoriously intricate. The defense will leverage this complexity to argue that any improper unbundling of E/M services resulted from confusion, not fraud.
Vohra’s system allegedly appended Modifier 25 automatically when an E/M service and a procedure occurred on the same day. The defense will likely frame this automation as a flawed but well-meaning effort to ensure physicians received credit for the full scope of their work. Determining when an E/M service is “significant and separately identifiable” is often a judgment call, and even compliant practices can struggle to apply the rule consistently.
In fact, the complaint cites an internal Vohra audit showing a 30% error rate in Modifier 25 usage. The defense will use this to underscore the point: this was not concealment, but self-monitoring—an effort to identify and correct billing mistakes. That kind of internal review, they’ll argue, is inconsistent with fraudulent intent.
Comparisons to Other EMR-Related FCA Cases
The allegations against Vohra Wound Physicians fit a growing pattern in FCA enforcement—targeting providers whose electronic medical records (EMRs) contribute to systematic overbilling. Recent cases underscore how the Department of Justice is increasingly scrutinizing how EMR design influences coding behavior.
In 2024, University of Colorado Health (UCHealth) paid $23 million to resolve FCA allegations that its hospitals upcoded emergency department visits. The government alleged that UCHealth’s billing software applied automatic coding rules that inflated visit levels beyond what clinical documentation supported—particularly CPT code 99285. CMS analytics had flagged the system as a “high outlier,” prompting further investigation.
Like Vohra, the UCHealth case centered on software logic that drove elevated billing. The difference lies in intent: UCHealth settled without admitting fault, whereas the Vohra complaint asserts that the company intentionally configured its EMR to eliminate lower-level debridement options and guarantee maximum reimbursement. Both cases, however, reflect the government’s growing reliance on data analytics to identify outliers and trace systemic overbilling back to EMR functionality.
In United States ex rel. Schieber v. Homecare Homebase, the target was not a provider but an EMR vendor. A whistleblower alleged that the home health software prompted clinicians to increase planned visits to trigger higher reimbursement tiers. DOJ intervened, and a federal court allowed the case to proceed, holding that EMR design could, by itself, lead to false claims. That case is instructive for Vohra: though Vohra’s EMR allegedly removed coding discretion rather than prompting it, the result—software-influenced overbilling—is analogous. Both cases suggest that companies can be held liable not only for user behavior but also for how their technology shapes that behavior.
Implications for Future FCA Enforcement and Compliance
The Vohra complaint underscores a central theme in recent enforcement: EMR functionality must not drive coding — if the EMR routinely generates high-level codes regardless of actual clinical inputs, enforcement risk rises sharply.
Providers must ensure that software reflects actual care, not merely revenue-maximizing assumptions. That includes regular internal audits of EMR logic and billing outputs. With enforcement agencies increasingly adept at using data analytics, patterns such as 100% surgical debridement billing or ubiquitous Modifier 25 usage will quickly attract attention.
The Vohra allegations highlight a toxic culture: one where clinical discretion was allegedly subordinated to revenue goals. That’s a red flag. Performance targets should align with patient care and regulatory norms—not merely financial outcomes. Otherwise, the organization risks incentivizing the very conduct the False Claims Act is designed to punish.
Perhaps most fundamentally, the case illustrates that documentation remains the first and best defense. If a provider is performing frequent, high-intensity procedures—such as weekly surgical debridements—there must be detailed, patient-specific records explaining why each procedure was necessary. Templated notes and copy-paste entries invite skepticism, especially when they track billing codes more than clinical progress.
In the absence of supporting evidence such as photos, wound measurements, or clinical rationale, DOJ is more likely to assert that nothing was done or that care was unwarranted. Generic boilerplate will not suffice. As enforcement agencies increase scrutiny of templated EMR entries, providers must ensure that documentation reflects individualized medical judgment—not just preloaded billing narratives.
Conclusion
The DOJ’s case against Vohra Wound Physicians Management reflects continued scrutiny of tools and corporate policies that shape billing behavior. The government may be signaling a broader enforcement philosophy: providers cannot insulate improper conduct behind EMR configurations or internal protocols.
