Updated February 18, 2026
CMS has contracted with Acumen, LLC to develop episode-based cost measures for potential use in the Merit-based Incentive Payment System (MIPS) to meet the requirements of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The measures undergo field testing before consideration of their potential use in the cost performance category of MIPS. Currently under development is a Non-Pressure Ulcers episode-based cost measure.
Previous field testing for the Non-Pressure Ulcers episode-based cost measure took place in early 2024. Field testing reports are now available through February 27, 2026. APMA urges members to log in to their account on the Quality Payment Program website to review any report they may have received.
You may provide feedback via the 2026 Field Testing Feedback Survey now through 11:59 PM ET on February 27, 2026. Use this general field testing feedback survey to provide your input on the measures, their specifications, the Field Test Reports, or other field testing materials. Clinicians providing feedback can review the survey questions via the 2026 Cost Measures Field Testing Survey (PDF), in advance of responding online.
Clinicians and clinician groups meeting the minimum number of 20 episodes for a measure will receive a Field Test Report with information about their cost performance. This information is for field testing purposes only. The measurement period for these Field Test Reports is January 1 to December 31, 2024. Please refer to the Field Test Report Access User Guide for guidance on accessing your Field Test Report.
Beginning January 29, 2026, the Quality Payment Program (QPP) Cost Measure Information pages will include updated information on the measure development process, draft measure specifications, an updated guide on accessing your field test report, and more.
Webinars:
Additional 2026 CMS field testing resources::
Field Test Reports for eligible clinicians and clinician groups are now available on the QPP website through February 27, 2026. If you think you may have received a Field Test Report based on the information about the measures, please register for an account on the QPP website.
Please note that clinicians, non-clinicians, and other interested parties who do not receive Field Test Reports can review any mock reports and all supplemental materials provided above (e.g. measure specifications and testing information).
Reminder: The Non-Pressure Ulcers episode-based cost measure is currently under development.
Note: This measure follows the Chronic Condition Cost Measure Framework.
1. What are trigger and confirming codes?
The start or continuation of a clinician group’s management of a patient’s non-pressure ulcers is identified by the appearance of a pair of services within a certain amount of time of one another: a trigger code followed by a confirming code. For the Non-Pressure Ulcers measure:
The specific CPT/HCPCS trigger and confirming codes for the Non-Pressure Ulcers episode-based cost measure are available here and on the QPP Cost Measure Information pages beginning January 29, 2026.
2. How are clinicians attributed the Non-Pressure Ulcers episode-based cost measure?
Any practice or individual clinician with at least 20 attributed episodes during the measurement period (January 1–December 31, 2024) should have received a Field Test Report through the QPP website. If any podiatrists or wound care practitioners meet this case minimum by providing the appropriate trigger and confirming services for non-pressure ulcer episodes, they would be attributed the measure, and therefore should have received a Field Test Report.
3. How were clinicians identified to participate in field testing (i.e., receive a Field Test Report through the QPP website)?
Clinicians with at least 20 episodes meeting the attribution criteria during the measurement period, January 1–December 31, 2024, should have received a Field Test Report. Field Test Reports for eligible clinicians and clinician groups became available through the QPP website beginning January 29, 2026.
The Non-Pressure Ulcers episode-based cost measure would be attributed to any group practice TIN when the trigger and confirmatory codes are met. An individual clinician (TIN-NPI) within that group could be attributed an episode if they bill at least 30 percent of the trigger or confirmatory services during an episode of care.
Field testing—a process which includes distributing informational reports to clinicians and soliciting comments from the public via an online survey—is a critical part of the measure development process. During field testing, episode-based cost measure workgroup members and the broader public alike have an opportunity to provide feedback and comments on the draft measure specifications and testing results to-date, which the clinician expert workgroup will then review as they consider refinements to the measures.