The Wound Care Reckoning: Defending Practices After Medicare’s 2026 Skin-Substitute Cut and the $4 Billion Takedown

Christopher T. Grohman, Partner | Benesch, Friedlander, Coplan & Aronoff LLP

Christopher T. Grohman is a partner in the Chicago office of Benesch, Friedlander, Coplan & Aronoff LLP, where he defends healthcare providers and other companies in False Claims Act investigations, government audits, Medicare recoupment actions, and criminal healthcare fraud prosecutions. He has first-chaired hundreds of Medicare administrative law judge appeals, with a focus on wound care, home healthcare, and hospice. He previously served as an Assistant United States Attorney for the Northern District of Illinois.

• Education & Credentials

Mr. Grohman earned his J.D. from Harvard Law School in 2006 and his B.S. in Economics, summa cum laude, with a concentration in Finance and a minor in Mathematics, from the Wharton School of the University of Pennsylvania in 2003. He clerked for the Hon. Algenon L. Marbley of the U.S. District Court for the Southern District of Ohio (2006–2007) and for the Hon. Ann Claire Williams (ret.) of the U.S. Court of Appeals for the Seventh Circuit (2009–2010). He is admitted to practice in Illinois and California, before the U.S. Courts of Appeals for the Sixth and Seventh Circuits, and in the U.S. District Courts for the Northern District of Illinois, the Southern District of Ohio, and the Eastern and Western Districts of Wisconsin.

• Recognition & Leadership

Mr. Grohman is ranked by Chambers USA in Litigation: White-Collar Crime & Government Investigations (Band 4, 2026) and was named to the Legal 500 City Elite in 2026. He has been recognized as an Illinois Super Lawyer in Criminal Defense: White Collar (2023–2025), as a Leading Lawyer (2019–2021), and by Crain’s Chicago Business as one of its Notable Leaders in Accounting, Consulting & Law (2024). During his government service, the United States Postal Inspection Service named him Prosecutor of the Year in 2014, and he received a 2013 award from Chicago Crime Stoppers.

• Professional Involvement

Mr. Grohman teaches Federal Criminal Law as an adjunct professor at the University of Illinois Chicago School of Law and previously taught legal drafting as an adjunct professor at DePaul University’s law school. He has also served as an instructor at the Federal Law Enforcement Training Center and the National Advocacy Center. He is a member of the American Bar Association, where he has served as Vice-Chair of the Young Lawyers Division’s Criminal Justice Committee, as well as the Federal Bar Association, the Chicago Bar Association, the Seventh Circuit Bar Association, and the Just the Beginning Foundation. His recent speaking engagements include “Government Investigations in the Long-Term Care Space” (2023) and “Representing Whistleblowers During Internal Investigations” (2026).

• Experience

Mr. Grohman’s healthcare practice centers on Medicare compliance and fraud defense. At Benesch, he led the team that secured the dismissal of all criminal charges against the owner of CarePlus Hospice Services, Inc. in a California prosecution alleging more than $7 million in fraudulent hospice billing, and he has handled dozens of federal and state False Claims Act investigations involving Medicare overbilling and other allegations. Earlier in his career, he defended a podiatrist and related company accused of more than $70 million in Medicare fraud tied to a computerized medical records system, obtained probation for an internal medicine physician accused of fraudulently billing Medicare and private insurers more than $3 million, defended a nursing home group in a federal False Claims Act investigation of “worthless care” allegations, and obtained a restraining order preventing the State of Illinois from withholding Medicaid funds from the state’s largest Medicaid provider. He was also lead appellate counsel in United States v. Borassi, a leading Seventh Circuit decision on the safe harbor under the anti-kickback provision of the Medicare fraud statute.

Beyond healthcare, Mr. Grohman has defended matters brought by DOJ, the SEC, the CFPB, and the CFTC, and has conducted internal investigations for Fortune 500 companies involving accounting fraud, executive embezzlement, theft of trade secrets, and FCPA issues. An experienced trial lawyer, he tried seven jury cases as a federal prosecutor and more than a dozen additional trials in private practice, including an eight-day federal jury trial that ended in a complete acquittal on all charges.

Rachel Hold-Weiss, Partner | Benesch, Friedlander, Coplan & Aronoff LLP

Rachel Hold-Weiss is a partner in the Healthcare Practice Group of Benesch, Friedlander, Coplan & Aronoff LLP in New York. She represents healthcare providers through Medicare audits and appeals, federal and state investigations, and fraud and abuse matters, including reviews by the HHS Office of Inspector General, the New York State Office of the Medicaid Inspector General, and CMS Medicare Administrative Contractors. A licensed physician assistant since 1996, she brings clinical training to a regulatory, transactional, and litigation practice centered on post-acute and long-term care providers.

• Education & Credentials

Ms. Hold-Weiss received her J.D. from Fordham University School of Law and her B.S., cum laude, in Physician Assistant studies from Touro College. Before practicing law, she worked as a physician assistant in inpatient and outpatient clinical settings, and she has been licensed as a physician assistant in New York since 1996. She is admitted to practice in New York and the District of Columbia and before the U.S. District Courts for the Southern and Eastern Districts of New York.

• Recognition & Leadership

Ms. Hold-Weiss is listed in The Best Lawyers in America for Health Care Law (2025–2027), has been recognized by Chambers USA as a top up-and-coming health care attorney in New York, and is rated by The Legal 500 United States as a national leader in the healthcare field. She serves on the Board of Trustees of the Hospice and Palliative Care Association of New York State and on the Board of Trustees of Community Health Accreditation Partner (CHAP).

• Professional Involvement

Ms. Hold-Weiss is a member of the American Health Law Association and the National Alliance for Care at Home. She speaks frequently on government audits and enforcement, with recent presentations including “What To Do When the Spotlight Finds You” (2026), “The Government is Coming, the Government is Coming!” (2024), “Home Health and Hospice in the Government Crosshairs” (2024), “TPEs, SMRCs and UPICs Oh My! – How to Successfully Manage Appeals” (2023), and “Administrative Appeals: Strategies for Success in UPIC, ALJ and MAC Appeals” (2023). She was featured on the American Health Law Association’s “Speaking of Health Law” podcast episode “Audit Defense: What Health Care Providers and Attorneys Need to Know” (2026), and Axios quoted her in 2026 on Medicare’s cuts to bioengineered wound care.

• Experience

Ms. Hold-Weiss has represented many providers through the Medicare audit and appeals process and regularly defends physicians and healthcare organizations in fraud and abuse matters involving anti-kickback, self-referral, false claims, corporate practice of medicine, and fee-splitting issues. She also advises on Medicare and Medicaid survey and reimbursement issues, designs and implements compliance programs, and conducts compliance audits.

Her clients include nonprofit and for-profit hospices and palliative care programs, home health agencies, skilled nursing and assisted living facilities, physicians, physician practices, and physician practice management companies. She represents investors, owners, and operators in regulatory and corporate due diligence, restructurings, sales, and acquisitions, and advises on certificate of need, facility and professional licensure, and healthcare privacy and security. Before joining Benesch in 2023, she was a partner at Arent Fox, and she previously served as Associate General Counsel and Corporate Compliance Officer for the Personal-Touch Home Care companies, a home care company with operations in 11 states.

SESSION 1 – How the Government Builds a Skin-Substitute Fraud Case Against Wound-Care Practices | Rachel Hold-Weiss & Christopher T. Grohman | 12:00pm – 1:00pm

This session walks through how the federal government finds, investigates, and prosecutes Medicare skin-substitute fraud. Attorneys will learn how data analytics start an investigation, which legal theories drive today’s prosecutions, and which billing patterns act as red flags in claims review. Attendees leave able to recognize the evidence these cases are built on and to counsel clients on the conduct that turns a compliance problem into criminal exposure.

BREAK | 1:00pm – 1:10pm

SESSION 2 – Payment Suspensions, Revocations, and Rebuilding Wound-Care Billing After the 2026 Cut | Rachel Hold-Weiss & Christopher T. Grohman | 1:10pm – 2:10pm

This session covers what happens to wound-care practices after the 2026 cut: Medicare payment suspensions, the expanded grounds CMS can use to revoke a provider’s enrollment under 42 C.F.R. § 424.535, and the corrective-action path back to reenrollment. Attorneys will learn how withdrawn Local Coverage Determinations, the collapse of old billing habits, and AI-driven prepayment review combine into cascading liability. Attendees leave knowing the documentation requirements, how suspensions and revocations work, and the steps needed to rebuild a compliant billing program.