April 1, 2024

APMA President Lawrence Santi, DPM, and Senior Medical Director Dyane Tower, DPM, MPH, MS, CAE, participated in a recent Clinician Expert Workgroup meeting with Acumen, LLC, a third-party entity contracted by CMS to develop episode-based cost measures for potential use in the Merit-based Incentive Payment System (MIPS). The Non-Pressure Ulcers measure currently under development will impact podiatrists in future MIPS Performance Years, if approved.

While APMA supports 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 MIPS cost performance category.

In this meeting and recent comment letter, APMA urged 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 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 the comment letter and other past letters in full, visit www.apma.org/CommentLetters.