I have blogged a lot about the boring topic of Medicare’s contract with Acumen to develop a cost measure for “non-pressure” ulcers (which means diabetic foot ulcers, venous leg ulcers, arterial ulcers, and “generic” chronic ulcers – surgical wounds and traumatic wounds are not included.)
Kara Couch and I represented the Alliance of Wound Care Stakeholders on Acumen’s Cost Measure Work Group for this topic. Many practitioners in different specialties and many content experts donated their time to this thanks to the advocacy of the Alliance as well as the American Podiatric Medical Society and others. In fact, the cost measure effort is one of the most powerful examples of why clinical societies and manufacturers need to support the work of the Alliance. One of the tasks the Work Group members did was to make sure that the codes for important treatments – some of which are new therapies – were not left off Medicare’s list of wound treatments, and that those charges were allocated correctly (at least, insofar as we were able.). We did what we could to ensure that patient and wound complexity were represented so that the need for advanced therapeutic options was understandable. The Alliance spent hours in meeting with Acumen, wading through complex lists of codes and collaborating with other member organizations. This is a task that would normally be handled by a physician medical specialty society – the way that the APMA represents podiatrists. Without a specialty designation for the other practitioners in wound care, this vital work would simply not get done without the Alliance.
In a letter submitted to Acumen’s MACRA Cost Measures Support Team and its Non-Pressure Ulcers Episode-Based Cost Measure Clinician Expert Workgroup, the Alliance provided feedback on the groups’ revised non-pressure ulcers episode-based cost measure. The measure is in the process of being refined following the Alliance’s previous advocacy outreach flagging significant methodology flaws and inaccuracies. The Alliance recorded its support for several of the updates but also submitted a number of clarity-seeking questions and voiced ongoing concerns with the measure’s cost allocation and claim attribution data — both of which are essential to an accurate and effective measure.
This cost measure could help or hurt a wound care practitioner – depending on some very complicated math inside the Merit Based Incentive System (MIPS). While the 2026 Acumen effort was better than the 2024 project, many areas of concern persisted having to do with “attribution” of charges which may have been out of the control of the practitioner (e.g., hospitalizations many miles away from the practitioner’s office or long after the patient had been discharged from the practice). We remain particularly concerned about the complete lack of “actionable items” based on a practitioners’ cost report. If your costs are determined to be higher than the practitioners are deemed your “wound care peers” (another confusing question), there is nothing specific you can do about it other than reduce services- at least based on the current report.
The Medicare cost measure for non-pressure ulcers is some of the messiest “sausage making” inside CMS. It’s hard to explain in simple language and the impact of the work is hard to quantity. What you can be sure of is that if we as an industry do nothing to respond to these issues, practitioners and patients will be hurt. I am grateful that the Alliance exists to tackle these complex (and generally thankless) tasks.
Caroline
Related posts:
- CMS Press Release: Prepare for 2026 Field Testing of Episode-Based Cost Measures – Caroline Fife M.D.
- Here We Go Again: CMS is Testing a New “Non-Pressure Ulcer” Cost Measure – Caroline Fife M.D.
- Here are the Specific Questions That CMS is Asking Regarding the Development of the “Non-Pressure Ulcer” Cost Measure – Caroline Fife M.D.
- On Feb 1st, CMS Started Testing the “Non Pressure Ulcers Episode-Based Cost Measure.” What the Heck is That, and Why Should You Care? – Caroline Fife M.D.
- Medical Specialty and Total Per Capita (Medicare) Cost (Drink Coffee Before You Try to Read This) – Caroline Fife M.D.
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