Non-Pressure Ulcers Episode-Based Cost Measure

On March 14, APMA submitted comments to Acumen expressing concern regarding the field testing results of the Non-Pressure Ulcers Episode-Based Cost Measure. Although APMA is supportive of a potential episode-based cost measure related to podiatric practice, APMA would like to have more clarity and understanding of this cost measure before it is considered any further for use in the cost performance category of the Merit-based Incentive Payment System (MIPS).

APMA urges Acumen to consider several aspects of the measure under development, such as trigger coding, attribution, sub-grouping of ulcers, risk adjustment, and quality measure alignment. APMA eagerly awaits additional information from and conversation with Acumen to address our concerns. APMA has requested a meeting with both Acumen and CMS to discuss the measure so there is a clear understanding of the issues associated with this cost measure.

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.