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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.
Field testing for the Non-Pressure Ulcers episode-based cost measure took place in early 2024.
Clinicians and clinician groups meeting the minimum number of 20 episodes for a measure received a Field Test Report with information about their cost performance. This information was for field testing purposes only. The measurement period for these Field Test Reports is January 1 to December 31, 2022.
Beginning February 1, 2024, the Quality Payment Program (QPP) Cost Measure Information pages included information on the measure development process, draft measure specifications (methods and codes), field test report user access, national testing results, field testing Frequently Asked Questions (FAQ), and more.
Field Test Reports for eligible clinicians and clinician groups became available on the QPP website beginning February 1, 2024. 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 did not receive Field Test Reports can review mock reports and all supplemental materials (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 180 days 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 February 1, 2024.
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, 2022) 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, 2022, should have received a Field Test Report. Field Test Reports for eligible clinicians and clinician groups became available through the QPP website beginning February 1, 2024.
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 provided feedback and comments on the draft measure specifications and testing results to-date, which the clinician expert workgroup then reviewed as they considered refinements to the measures.
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