(1) Continued development of wound care-relevant QCDR measuresOf primary concern is that the obligatory reporting of quality, resource use and clinical performance measures may not truly be indicative of our wound care work nor of the resources that we use to treat patients. We need outcome measures for advanced therapeutics like negative pressure and cellular products to ensure we can tie the cost of these interventions to the improved outcomes achieved with them.
The Alliance is vitally interested in the possibility of improving reimbursement for wound care practitioners through group reporting of quality measures as a virtual group. We continue to monitor CMS policy in this area.
(2) Virtual Groups
(3) Enabling clinicians across the wound care team to qualify for the newly incentivized Medicare payment system.Wound care is a multi disciplinary field. So another concern unique to the wound care clinician space is that as we transition to APMs and MIPs, not all clinicians across the wound care team will qualify for the newly incentivized Medicare payment system. For example, physical therapists aren’t eligible to participate in the new payment paradigm for at least three years. This means inconsistent paradigms across a multi-disciplinary wound care team. While it is not at all envisioned that patient care will suffer, the documentation and reporting needs may differ across the MIPS-eligible practitioners and the non-eligible practitioners.
See the Alliance’s comments to regulatory agencies addressing development of wound-relevant quality measures.
The Alliance & Quality Measure Advocacy: HistoryThe Alliance of Wound Care Stakeholders has long advocated for quality measures that are more appropriate to the wound care space.
On January 1, 2017, CMS began a new method for determining Medicare Part B payments to Qualified Health Professionals such as physicians, podiatrists, and nurse practitioners. Most QHPs are now subject to the Merit Based Incentive Payment System (MIPS) that requires, among other things, the reporting of Quality Measures (QMs) and Clinical Practice Improvement Activities (IAs).
However, the transition away from volume towards value-based payment began in 2008 under the program that became the Physician Quality Reporting System (PQRS). From 2009 to 2013, the Alliance worked with member organizations and the U. S. Wound Registry (USWR), a PQRS reporting registry for wound care practitioners, to try to convince CMS to introduce well-designed, wound care relevant quality measures into the PQRS program.
The Alliance in conjunction with the USWR twice submitted measures to replace the badly designed ones during “open calls” for measures. Unfortunately, the national endorsement organization informed us that the data supporting interventions like diabetic foot ulcer off-loading were insufficient to meet quality measure endorsement standards because the clinical trials were too small.
In 2014, CMS created a new entity called the Qualified Clinical Data Registry (QCDR). QCDRs, usually run by medical specialty societies, could create and develop their own quality measures. Since Wound Care is not a specialty, CMS agreed (after much advocacy and education on the part of the Alliance) to allow the Alliance of Wound Care Stakeholders to act as a de-facto specialty society. The Alliance mobilized its membership and began wound care quality measure development in partnership with the USWR, a 501(c)(3) non-profit organization that has provided quality reporting for wound care practitioners since in 2008.
In the first year of the program, 2014, CMS recognized the USWR as a QCDR and approved 14 wound care relevant quality measures. In 2017, the USWR was among the first QCDRs recognized by CMS to report quality data under MIPS, with 14 wound care measures approved by CMS.