As detailed in the blog post " Understanding the WISeR Model: What Wound Care Providers Need to Know", starting on January 5, 2026, for dates of service on or after January 15, 2026, select items and services covered under Original Medicare are subject to prior authorization or pre-payment medical review under the Wasteful and Inappropriate Service Reduction (WISeR) Model.
Beginning in July 2026, the Centers of Medicare & Medicaid Services (CMS) and WISeR Model Participants implemented a process to automatically exempt qualifying WISeR Providers and Suppliers from prior authorization and pre-payment medical review after they demonstrate compliance with Medicare coverage, coding, and payment rules.[1]
For wound care providers, one of the most important aspects of the WISeR Model is the opportunity to earn an exemption from prior authorization and pre-payment medical review.
This exemption applies to all WISeR Select Items and Services, including applicable skin substitute applications - also known as cellular and/or tissue-based products (CTPs) or cellular, acellular, and matrix-like products (CAMPs) - and is informally referred to as “Gold Carding.”
Of note, WISeR applies only to the skin-substitute codes, indications, sites of service, and jurisdictions included in the current CMS operational guide and applicable Medicare coverage policy.
The WISeR Gold Card Is Automatically Earned - There Is No Separate Application
One of the most important things for providers to understand is that there is no application for Gold Card status.
A physician or other eligible provider cannot submit a request asking to be "Gold Carded" because they believe they meet the requirements. Instead, WISeR Participants assess their performance and add qualifying NPIs to the Exemption Status list on a quarterly basis.
The Participant will notify the provider or supplier before the applicable quarter begins. The notice will identify the effective date, duration, and reevaluation process.
Think of it as a recognition of a provider's track record, like: You have consistently demonstrated that your documentation and services meet Medicare requirements, so you have earned an exemption from the prior authorization process.
How Do You Qualify for the WISeR Gold Card?
CMS establishes the minimum baseline requirements for exemption:
- Submit at least 10 prior authorization requests for applicable WISeR Select Items and Services during the exemption assessment period.
- Achieve the applicable affirmation-rate threshold during that assessment period.
CMS establishes two minimum baseline requirements:
- 1. Submit at least 10 prior authorization requests across WISeR Select Items and Services during an exemption assessment period.
- 2. Achieve the applicable minimum prior authorization request affirmation-rate threshold during that assessment period.
WISeR Participants must apply these minimum requirements but may establish additional Participant-specific criteria.
The 10-request minimum applies across WISeR Select Items and Services; the requests do not have to be limited to skin substitute or CTP applications. Once earned, Exemption Status applies to all WISeR Select Items and Services, across Medicare Parts A and B and all sites of care—not only to the service category through which the provider qualified.
For wound care providers, this means that documentation supporting skin substitute and CTP applications becomes especially important.
The required affirmation rate may vary among WISeR Model Participants. As of August 2026, published Participant thresholds reviewed by WoundReference range from 80% to 90%. Requirements are subject to change. For example, a WISeR Participant requiring a 90% affirmation rate would require a provider to achieve at least a 90% affirmation rate on the required number of prior authorization requests.
Do not assume that the same threshold applies in every state or for every WISeR Participant. Each WISeR Model Participant may establish additional criteria within the parameters established by CMS.
Providers should visit their WISeR Model Participant's website for the specific Gold Card requirements, affirmation threshold, assessment methodology, and other program criteria applicable to their state.
WISeR Model Participants Guidance on Gold Card Eligibility
Build Your Gold Card Strategy Around Documentation
Because Gold Card status is earned through demonstrated compliance, organizations should build their documentation processes before a provider reaches the 10-request minimum.
For skin substitute/CTP applications, consider:
- Build a standardized documentation infrastructure. Establish a consistent workflow for documenting the clinical information needed to demonstrate medical necessity and meet applicable Medicare coverage requirements.
- Use documentation templates and checklists. Incorporate standardized templates and checklists for CTP and skin substitute applications to help ensure required elements are addressed every time.
- Audit 100% of applicable documentation while providers are working toward Gold Card status. Provider-level review can identify documentation gaps before they affect an affirmation rate.
- Audit in real time. Electronic audit systems can help identify missing or inconsistent documentation while there is still an opportunity to correct it.
- Track each provider's affirmation rate. Because Gold Card status is achieved at the individual NPI level, organizations should monitor performance at the individual provider level rather than relying solely on organizational performance.
- Continue auditing after Gold Card status is achieved. Gold Card status is not permanent. Continuing quarterly audits can help identify potential compliance issues before they jeopardize the exemption.
- Recognize provider achievement. Achieving Gold Card status represents a meaningful accomplishment and an opportunity to reinforce good documentation and compliance practices across the wound care team.
Gold Card Status Is Tied to the Individual Provider NPI
Gold Card status is granted at the individual National Provider Identifier (NPI) level, not at the facility or organizational level.
For example, if one physician in a wound care practice achieves Gold Card status, that does not automatically give the other physicians in the practice the same exemption.
Organizations should therefore track Gold Card progress and affirmation rates for each individual provider.
Once Exemption Status becomes effective, the provider should stop submitting WISeR prior authorization requests and submit claims through the standard billing process.
To ensure Exemption Status is recognized when a claim is submitted, the exempted provider’s NPI must be reported in the appropriate claim field:
- Office or home: rendering-provider field;
- Ambulatory surgery center: referring/ordering-provider field;
- Hospital outpatient department: operating-provider field.
How Long Does the Gold Card Last?
Once a provider achieves Exemption Status, the provider will maintain that status for at least one year, although a WISeR Model Participant may extend the exemption period at its discretion.
After the applicable exemption period, the WISeR Participant will reevaluate the provider's Exemption Status. As part of the reevaluation process, the Participant may issue no more than 10 Additional Documentation Requests (ADRs) per year to examine the provider's continued compliance with Medicare coverage criteria. Participants may also use other reasonable methods of reevaluation, provided those methods are disclosed to CMS and providers.
Importantly, Gold Card status does not mean the provider is permanently exempt from review. The exemption is intended to recognize a demonstrated record of compliance while allowing the WISeR Participant to periodically verify that the provider continues to meet Medicare coverage requirements.
If a provider loses Exemption Status following reevaluation, the WISeR Participant must notify the provider at least 60 days before the start of the next quarter. The notification must include the effective date of removal and information about how to re-earn Exemption Status.
The Gold Card Is Not a Free Pass
Achieving Gold Card status does not mean that Medicare coverage and documentation requirements no longer apply.
The provider remains responsible for meeting all applicable Medicare requirements and maintaining documentation to support the medical necessity and appropriateness of skin substitute and CTP applications.
In fact, organizations should view Gold Card status as a reason to strengthen - not relax - their documentation and compliance processes.
Key Takeaways
For wound care providers, Gold Carding represents an opportunity to reduce the administrative burden associated with WISeR prior authorization for skin substitute and CTP applications.
There is no application to complete and no shortcut to achieving the status. It is earned by demonstrating consistent compliance.
The most effective strategy is to build strong documentation practices into the clinical workflow from the start, monitor each provider's affirmation rate, identify and correct documentation gaps in real time, and continue auditing after exemption status is achieved.
Because WISeR Model Participants may have different requirements and affirmation thresholds, providers should check with their applicable Participant for the most current Gold Card criteria.
The goal isn't simply to get the Gold Card. The goal is to build a wound care documentation process that consistently earns it - and keeps it.
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