🚨 New DOJ Indictments in Skin Substitute (CTP) Fraud: What Every Wound Care Provider Needs to Know

On June 30, 2025, the Department of Justice announced one of its largest-ever National Health Care Fraud Takedowns, including 324 defendants, with 96 clinicians-among them Nurse Practitioners-charged across 50 federal districts and 12 states. A particularly alarming takeaway: new criminal indictments in the skin substitute (CTP) space involving amniotic tissue products blog.smarttrak.com+9carolinefifemd.com+9intellicure.com+9.

Key Cases to Note

Paulino Gonzalez (Las Vegas, NV) A nurse charged in a $94 million scheme, allegedly receiving over $7.4 million in kickbacks for prescribing unnecessary amniotic allografts—billions of dollars billed to Medicare.

Mary Huntly, NP (Las Vegas, NV) Allegedly applied medically unnecessary amniotic grafts to patients—Medicare billed approximately $14.3 million, with over $9.1 million disbursed—again linked to kickbacks.

Ira Denny (Arizona) Accused of a massive $209 million scheme involving Medicare billing for unnecessary amniotic allografts, allegedly facilitated by salesperson-driven referral without independent medical evaluation.

Kontos, Kupetz & Kinds (Arizona) Linked to a staggering $1 billion conspiracy involving fraudulent allograft use in vulnerable, often hospice-based, patients including money laundering charges.

 Why This Matters to Kindling Clients

1. Financial & Legal Risks— Allograft-related fraud now triggers FBI and DOJ investigations-any questionable billing practices are under scrutiny nationwide.

2. Compliance Must be Proactive— Kickbacks aren’t always blatant. They can be disguised as referral fees, vendor sponsorships, or compensated advocacy. And billing for medically unneeded products is steeped in risk.

3. Documentation Is Your Shield— Proper charting isn’t optional, it’s essential. All clinical support and training must align with federal LCDs, payer policies, and defensible clinical justification.

4. Vendor Relationships Require Guardrails— Any financial ties to vendors must reflect fair market value (FMV), be transparent, and uncompensated for product selection or volume. No hidden incentives.

What Kindling Can Do for You

With decades of experience in wound care operations, documentation training, and compliance:

• We help you audit clinical workflows and billing around allografts

• We ensure documentation meets federal and payer standards, including LCDs

• We support vendor independence, fair value compensation, and audit readiness

This isn’t about fear, it’s about resilience. When you partner with Kindling, you get clarity you can defend and support you can trust.