On December 23, 2024, APMA submitted comments to both the Partnership for Quality Measurement (PQM) and CMS Pre-Rulemaking Measure Review Committee providing feedback regarding the Non-Pressure Ulcers episode-based cost measure currently under development.
APMA urges PQM and CMS to consider several aspects of the measure under development which include accuracy, lack of clarity over methods, lack of testing, and ability to reflect the best interest for DPMs. APMA also has concerns about the inequity for doctors’ control over treatment costs, and how it is assigned to the doctors. APMA strongly recommends additional testing before there is further consideration.
For more information on the Non-Pressure Ulcers Episode-Based Cost Measure, visit www.apma.org/npucost. To read this letter and other past letters in full, visit www.apma.org/CommentLetters.