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APMA Presses CMS and Acumen for Improvements to Proposed Non-Pressure Ulcer Episode-Based Cost Measure Following Field Testing Report Review 

  • Mar 9, 2026

In its latest comments to Acumen and CMS regarding the development of the Non-Pressure Ulcer Episode-Based Cost Measure (NPUECM), APMA continues to advocate for podiatrists. APMA has been closely involved with this measure throughout its development and refinement, given its high likelihood of impacting MIPS-participating podiatrists and their MIPS bonus or penalty to future Medicare reimbursements. While significant improvements have been made with the measure to ensure more accurate assignment of services and easier-to-understand reports and scores, APMA remains concerned and has requested a meeting with Acumen.

Members can read this letter in full along with all other past comments at www.apma.org/CommentLetters. Any questions or concerns related to this issue should be directed to mips@apma.org.