As a result of APMA's advocacy, the episode-based cost measure related to Non-Pressure Ulcers, for potential use in the Merit-based Incentive Payment System (MIPS), was not part of the recently released Medicare Physician Fee Schedule for Calendar Year 2026 proposed rule. Over the past 18 months, APMA represented podiatrists on the related Clinician Expert Workgroup (CEW) and repeatedly urged CMS and Acumen to reconsider several aspects of the measure under consideration including trigger coding, attribution, sub-grouping of ulcers, risk adjustment, and quality measure alignment.
As CMS and Acumen continue development on the Non-Pressure Ulcers episode-based cost measure, APMA will continue to advocate on behalf of its members. APMA Vice President, Clinical Affairs and Medical Director Dyane Tower, DPM, MPH, MS, CAE, will serve as Co-Chair of the CEW while APMA Coding Committee Chair David Freedman, DPM, was recently selected to join the group as well.
While APMA supports a potential episode-based cost measure related to podiatric practice, APMA needs more clarity and details before a cost measure is further considered for use in the MIPS cost performance category.
For more information on the Non-Pressure Ulcers Episode-Based Cost Measure, visit www.apma.org/npucost. Members can read this letter and other past advocacy letters at www.apma.org/CommentLetters. Contact the APMA Advocacy Department with any questions or concerns.