Non-Pressure Ulcer Episode-Based Cost Measure | Practicing DPMs | APMA
Non-Pressure Ulcer Episode-Based Cost Measure

Episode-Based Cost Measure Under Development: Non-Pressure Ulcers

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 will 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 will take place February 1–29, 2024.

Introduction to Field Testing

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 will be 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 will include 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 will be available on the QPP website beginning February 1. If you think you might receive a Field Test Report based on the information about the measures, please register for an account on the QPP website now!

  • CMS encourages you or your group’s authorized representative to create an account if you do not already have one. More information regarding registering for an account is available in the QPP Access User Guide.
  • If you have any questions or require assistance, contact the QPP Service Center via telephone at 866-288-8292 or via email at QPP@cms.hhs.gov.

Please note that clinicians, non-clinicians, and other interested parties who do not receive Field Test Reports can also review mock reports and all supplemental materials (e.g., measure specifications and testing information) to provide feedback on the draft measure.

Non-Pressure Ulcers Episode-Based Cost Measure

Reminder: The Non-Pressure Ulcers episode-based cost measure is currently under development. If you have feedback related to the measure specifications, please let APMA know so we can advocate appropriately. Email mips@apma.org with your feedback and suggestions, in addition to providing feedback to CMS through the general 2024 Field Testing Feedback Survey.

Note: This measure follows the Chronic Condition Cost Measure Framework.

Frequently Asked Questions

  1. What are trigger and confirming codes?
  2. How are clinicians attributed the Non-Pressure Ulcers episode-based cost measure?
  3. How are clinicians identified to participate in field testing (i.e., receive a Field Test Report through the QPP website)
  4. What is field testing?
  5. How can I provide feedback?

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:

  • A trigger code is any code from a set of CPT/HCPCS codes for clinically relevant outpatient services (outpatient evaluation and management codes [E/Ms], measure-specific outpatient E/Ms) when accompanied by an ICD-10 diagnosis code indicating relevant ulcers.
  • A confirming code is either any code from the same trigger set of CPT/HCPCS codes for clinically relevant outpatient services when accompanied by an ICD-10 diagnosis code indicating relevant ulcers, or a code from an additional set of CPT/HCPCS codes (for rehabilitation services, wound debridement, skin grafts, wound modalities, or wound dressing products) when accompanied by an ICD-10 diagnosis code indicating relevant ulcers.

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.

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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) will receive 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 receive a Field Test Report. 

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3. How are 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, will receive a Field Test Report. Field Test Reports for eligible clinicians and clinician groups will be available through the QPP website beginning February 1.

The Non-Pressure Ulcers episode-based cost measure will be attributed to any group practice TIN when the trigger and confirmatory codes are met. An individual clinician (TIN-NPI) within that group can be attributed an episode if they bill at least 30 percent of the trigger or confirmatory services during an episode of care.

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4. What is field testing?

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 this time, episode-based cost measure workgroup members and the broader public alike can provide feedback and comments on the draft measure specifications and testing results to-date, which the clinician expert workgroup will then review and consider refinements to the measures.

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5. How can I provide feedback?

Anyone, regardless of whether you receive a report, is invited to provide feedback. You can provide feedback on the draft measures specifications through the general 2024 Field Testing Feedback Survey, which will open at the start of field testing on February 1. A document containing specific questions from this survey is available here and on the QPP Cost Measure Information page for reference while reviewing the materials. 

There will also be a specific Person and Family Engagement Field Testing Survey for patients or caregivers with lived experience with Non-Pressure Ulcers. A document containing specific questions from this survey is available here and on the QPP Cost Measure Information page.

All survey questions will be optional, and you may attach a comment letter (as a PDF or Word document) in addition or as an alternative to responding to the survey questions. All feedback may be submitted anonymously. Participation is voluntary. 

Public feedback on cost measures is vital in the measure development process, and we hope you will consider sharing your input. 

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