July 1, 2024

On June 28, APMA communicated directly to CMS its ongoing concerns related to the development of the Non-Pressure Ulcer Episode-Based Cost Measure. These concerns follow previous formal comments and a meeting with Acumen, LLC, which CMS contracted to develop methodology for analyzing cost, as appropriate, through consideration of patient condition groups and care episode groups for this and other Wave 6 measures. While APMA has numerous concerns related to this measure’s development following the field testing, we highlighted the following concerns as most pressing:

• lack of clarity in the feedback reports as to how a practice or clinician is determined to reasonably influence the frequency, intensity, or occurrence of the clinically related services provided to a non-pressure ulcer patient;
• lack of meaningful quality measures to link with the proposed non-pressure ulcer episode-based cost measure, particularly as existing measures are topped out and subsequently removed and not applicable to all patients with non-pressure ulcers; and
• as the reports are currently structured and designed, the average clinician will not be able to understand or meaningfully act on the cost reports they receive if attributed under this measure, whether correctly or incorrectly.

APMA has worked directly with Acumen, with two podiatric physician representatives participating on the Clinician Expert Workgroup: APMA President Lawrence Santi, DPM, and APMA Senior Medical Director, and Director of Clinical Affairs Dyane Tower, DPM, MPH, MS, CAE.

Read this letter in full at www.apma.org/commentletters, as well as all other past comment letters. Please contact APMA’s Health Policy and Practice department with any questions or concerns.