The chronic wound, managed

Keep the person whole.
At home.

KEEP is the benefit manager built for the chronic wound. A home-care spine, an evidence formulary, and the one record claims can't see: whether the wound closed and the limb was kept.

North-star metric: limbs kept. Not dollars. The dollars follow.

Fig. 1 One diabetic foot ulcer, two paths
Reading the kept path

WOUND STATUS wk 0 4 8 12 wk 16 the fork open DFU Limb kept wound closed Major amputation ~56.6% 5-yr mortality
A managed wound benefit steers the patient onto the kept path: closure, and a limb preserved. The lower branch is the unmanaged risk.
Hover a branch · Enter toggles ·6
The stakes

A wound is not a billing line. For too many patients it is the start of a countdown.

Five years after a major diabetic-foot amputation, more than half of patients are gone6. And the people losing limbs are not chosen at random7. Chronic wounds already cost Medicare more than $28 billion a year across 8.2 million beneficiaries, roughly one in seven8. KEEP exists to bend that countdown the other way.

Five-year mortality, after a major DFU amputation

56.6%die within five years6
Major DFU amputation56.6%
All-cancer pooled average~31%
Breast / prostate / colorectallower still

And it falls unevenly. Black patients are amputated 2–4x the rate of white patients7, with less revascularization before amputation.

Why now

A market broke, got fraudulent, and came to a reckoning in the same eighteen months.

Skin-substitute spend ran away, the courts caught a billion-dollar scheme, and CMS slammed the price. Each one alone would matter. Together they open the door for a manager.

01 · THE RUN-UP
$256M → >$10B

About 40x in five years

Medicare Part B skin-substitute spend went from $256M in 2019 to over $10B in 2024 while the patient count only roughly doubled1. Dollars outran people by 20 to 1.

02 · THE FRAUD
$1.2B

Adjudicated, not alleged

An Arizona wound-graft scheme drew guilty pleas and 15.5- and 14-year sentences, plus $309M in civil recovery5. The money was real. So was the harm.

03 · THE CMS FIX
$127.14 /sq cm

A ~90% cut, effective Jan 1, 2026

CMS replaced ASP+6% (average sales price plus 6%) with a single flat rate of $127.14/sq cm, paid as an incident-to supply at the same rate in office and hospital outpatient. About $19.6B saved in CY2026 alone23.

Fig. 2

Dollars outran patients, 2019–2024

Medicare Part B skin-substitute spend, plotted against the patient count it was meant to track.1

~40×
spend growth · patients only ~2×
PART B SPEND ($B)
Each column is a year of spend; the gold line is the same population, indexed. The gap between them is the overutilization a benefit manager exists to close.
OIG endpoints exact · intermediate years interpolated1
The gap CMS left

CMS fixed the price. It did not fix the coverage.

The new rate caps dollars per square centimeter. It says nothing about which product, which wound, how many applications, or how large a graft. And on December 24, 2025, the seven Medicare Administrative Contractor (MAC) coverage rules that would have answered those questions were withdrawn4.

CMS handled this · the price

What is now capped

  • Dollars per square centimeter, flat at $127.142
  • Same rate in office and hospital outpatient
  • Paid as an incident-to supply, not a marked-up product
No regulator yet · the coverage

What is still unguarded

  • Which product, of 361 on the list
  • Which wound, which indication, medical necessity
  • How many applications, how large a graft. A flat per-cm² rate even rewards larger grafts

CMS capped the dollars-per-unit and walked away from medical necessity. No regulator has stepped in to fix the other side. That is the benefit manager's job.

The model

KEEP manages the episode, not a product.

The skin substitute is the trigger, not the prize. KEEP runs the whole wound episode — from home nursing through escalation and step-down — inside one managed pathway. The formulary and the closure registry sit inside it, not beside it.

A manager that touches only the formulary manages the loud ten percent and leaves the real money — and the real outcomes — untouched. So KEEP owns one disease, vertically, all the way down: home nursing, medications, labs and the vascular gate, offloading, and the right level of care escalated up or stepped down as the wound moves. One disease. Not all of healthcare.

Fig. 3

The wound episode, escalated up and stepped down

One managed pathway across levels of care. Ancillary services are the levers; the formulary and registry sit inside; everything is orchestrated to one number.

limbs
kept
the one number every level is orchestrated to
ESCALATE · LIMB THREATENED DE-ESCALATE · WOUND CLOSING LEVEL 4 · HIGHEST ACUITY Vascular & surgery · hospital admission · HBOT When the limb is threatened — revascularize, debride, admit. LEVEL 3 · SPECIALTY ESCALATION Vascular workup · infectious disease · advanced product VASCULAR GATE · ABI / studies HARD GATE → No graft on a limb with no blood supply. LEVEL 2 · HOME-BASED ACTIVE MANAGEMENT Tele-wound MD/NP supervision · the credentialed home network Evidence formulary Closure registry LEVEL 1 · HOME MAINTENANCE Closed wound, kept whole at home — monitor, prevent recurrence. THE LEVERS Home-nurse monitoring Medications · A1c Labs & cultures Vascular studies Offloading / DME Nutrition · behavioral Care coordination Transportation ORCHESTRATED TO Limbs kept closure rate, then cost — in that order, on purpose.
Levels of care are the lever; limbs kept is the result. The graft is one slice of a dollar. Total wound burden runs $28B+ in Medicare alone8, most of it in visits, escalations, and avoided amputations. You cannot capitate a product; you capitate the episode.
Hover / focus a level
Adds, up

The right care

  • More home-nurse monitoring — the visit that catches infection early
  • The vascular gate before any advanced product is approved
  • Offloading, correct antibiotics, glycemic and nutrition support
  • Escalation to vascular, surgery, or hyperbaric oxygen (HBOT) the moment the limb is threatened
Removes, down

The wasteful care

  • Over-grafting — product applied where it cannot help
  • Grafts on limbs with no blood supply to heal them
  • Applications beyond evidence, larger grafts the flat rate rewards
  • Wound-center utilization the patient could get safely at home

Managing the right care up and the wasteful care down is what makes lead with limb preservation, savings follow true, not a slogan. The savings are the consequence of better care, never the goal we open with.

The risk ladder

KEEP climbs from administrative fees toward a capitated wound carve-out. You can only take a capitated rate if you can move the outcome, and the registry is how KEEP proves it. The carve-out is the wound condition only — condition cost of care, never total cost.

1

Admin / PMPM management fee

Formulary, evidence-aligned prior auth, network access, and the wound-spend diagnostic.

risk borne
2

Performance guarantees

Closure-rate and limb-preservation targets put fees at risk against real outcomes.

risk borne
3

Capitated wound carve-out (CCOC)

A per-member rate for the wound population, keeping the spread it saves. Precedent that payers will capitate a young vendor: Synapse Health / UnitedHealth, DME, 2026.

risk borne

Rung one starts with your own numbers. Open the wound-spend diagnostic →

The moat

Claims can't see whether a wound closed. KEEP owns the record that can.

A claim records that a graft was applied and paid for. It does not record whether the wound closed, whether the limb was kept, or whether a cheaper product would have closed it faster. Every incumbent shares that blind spot.

KEEP makes photographic, measurement-based wound documentation a network-contracting requirement — every wound, every visit. That produces the only closure-rate dataset segmented by product, provider, and wound type, owned by KEEP and reported to the payer: the record claims data can't supply.

The registry is the steerage engine. Once you can see which products and which providers actually close wounds, you point volume there, and the limb-preservation rate is what moves first. It is also what lets KEEP bear risk at all: you can only take a capitated rate if you can move the outcome, and you can only prove you moved it if you own the measurement.

And it is the defense. A UM rule copies in a quarter. A longitudinal closure registry, plus the home-care spine underneath it, takes years to build.

US Wound RegistryOwns risk-stratified closure benchmarks.
Net HealthOwns product utilization data.
Swift MedicalOwns objective wound imaging.
KEEPFuses closure rate by product and provider into payer purchasing and steerage, on the home-care spine. Today the pieces sit apart; no product on the market makes that fusion. That fusion is KEEP.
KEEP owns
  • The closure registry — the record, the risk-enabler
  • Tele-wound MD/NP supervision — the clinical brain over every case
  • The evidence formulary — which products earn their place
  • The steerage engine — volume goes to what closes
KEEP partners for
  • The hands-on home visits, through credentialed home-wound-care providers. KEEP does not employ a field workforce.
  • A paperwork-only manager can't move outcomes, so it is stuck at thin fees. An own-and-operate provider is labor-bound. The hybrid is the structure built to reach a capitated carve-out.

Be the brain and the scoreboard; rent the hands.

The north-star

What KEEP reports back is limbs kept.

Not dollars saved. A limb preserved. A wound closed. A person kept whole, at home.

The metric is limb-preservation rate, supported by closure rate, and only then by cost. Run the toggle: when a wound benefit is managed, the outcomes move first. The savings are the quiet consequence, and they come last.

Fig. 4

A wound population, unmanaged vs. managed

Limbs kept limb-preservation
Wound closure rate
Steered to home care
Wound spend the quiet one, last
A directional illustration, not a guarantee or a modeled figure. Outcomes move first; spend is the last line to move, on purpose.
Who it's for

Every payer. We start where the dollars are most exposed.

The genuinely unmanaged spend sits in commercial and Medicaid, where there is no CMS rate to cap it and no public dataset even sizing it. Medicare Advantage already manages this. We meet each payer where it actually stands.

Lead · 01

Commercial

Same clinical wound burden, no CMS rate to cap it, weak medical policy in many plans. The most exposed dollars, and the clearest first meeting.

Lead · 02

Medicaid MCOs

FFS segments and weak-policy states carry the same risk with no public number sizing it. A regional MCO without internal wound capability is the wedge buyer.

Then

Medicare Advantage

Already self-manages this through prior auth: only ~7% of FFS skin-sub spend despite over half the lives9. Pitched as managed services, the home spine, and the registry. Not a rescue.

Then

Medicare FFS

Got the price fix but still carries coverage-side risk: larger grafts, more applications. A managed pathway still has a job through the coverage gap.

The whole model, walked end to end. See the walkthrough →

Joe Nalley, operator THE OPERATOR Joe Nalley Founder, KEEP
The operator

Built by someone who has carried patients and built the businesses around them.

Joe Nalley built KEEP from inside the machinery of payer growth. Today he is Staff Vice President of Carelon Growth (Elevance Health), at national scale.

He founded and sold ClearBill, which returned $9.2M to payers in its first six months. He built and exited GetWell, a 13-location behavioral-health and substance-use provider that served more than 30,000 patients.

Across a career in care delivery and payer growth, he has been responsible for more than 200,000 lifetime patients served. KEEP is the benefit manager that work has been pointing toward.

$9.2M
returned to payers by ClearBill in its first six months
30,000+
patients across the 13-location GetWell network he exited
200,000+
lifetime patients served
The objections

The four questions payers ask first.

Fair questions, all four. Here are the straight answers.

Objection · 01"Why not just write a UM policy?"
A UM policy polices the graft; it cannot see whether the wound closed. It also copies in a quarter, so it confers no lasting edge. The closure registry and the home-care spine are what a policy can't replicate, and they are what actually keep limbs.
Objection · 02"Isn't this a denial machine?"
No. The model adds care: more home-nurse visits, tele-wound supervision, the vascular gate, photographic documentation at every visit. What it removes is waste, mostly over-grafting, and the number KEEP reports back is limbs kept, not claims denied.
Objection · 03"Why won't TurningPoint or Optum do this?"
They might try; TurningPoint already lists wound care across 42M lives. But horizontal UM has not shown the two things that move the outcome: a home-delivery spine and a closure registry. A rule book scales fast. A record of what actually closes wounds does not.
Objection · 04"Why would we capitate a young vendor?"
You wouldn't on day one, and KEEP doesn't ask you to. The ladder starts at an admin fee, puts fees at risk against closure and limb-preservation targets second, and treats capitation as the destination, not the ask. The precedent that payers will capitate a young vendor for a carve-out is recent: Synapse Health and UnitedHealth, DME, 2026.
The first meeting

Book the wound-spend diagnostic.

One condition, the diabetic foot ulcer. One artifact: your own 40x chart, built from public and plan-shareable data, so your plan sees its own exposure. No network required to produce it.

We open with limb preservation. We close with limbs kept. The savings are real, and they come last.