The Alliance of Wound Care Stakeholders has been a long time champion of quality measures for the wound care space. When CMS opened the door in 2014 to development of quality measures in conjunction with a Qualified Clinical Data Registry (QCDR), the Alliance – together with the U.S. Wound Registry (USWR) – developed 14 quality measures specific to wound management which were subsequently approved by CMS.
The enactment of the Medicare Access and CHIP Reauthorization Act (MACRA) in April 2015 ushered in a new chapter of Medicare physician reimbursement policy. With a focus on better care at lower costs, MACRA ties physician payment incentives and penalties to value, quality, performance and outcomes. As a way to improve patient care, measure the benefits of specific interventions, and incentivize clinicians for providing them, there has been an initiative to develop and report specific clinical “quality measures.” However, there are no quality measures relevant to wound care within the new reporting systems to link performance measures to reimbursement.
The value-based payment models being put in place today for clinicians – such as the Merit Based Incentive Program System (MIPS) and Alternative Payment Models (APMs) - do not adequately take into consideration the specialists and subspecialists who practice wound care. Under the current system, the obligatory reporting of quality, resource use and clinical performance measures do not capture a wound care clinicians’ outcomes or resource use. This can negatively impact their Medicare reimbursement.
There is a need for CMS and health policy makers to develop episode of care measures and/or chronic care models relevant to the care of patients with chronic wounds. The Alliance of Wound Care Stakeholders – representing a unified voice of the wound care provider community – regularly advocates on this issue.
- Comments to the Physician-Focused Payment Model Technical Advisory Committee (PTAC)
- Comments to AHRQ Technology Assessment on Skin Substitutes for Treating Chronic Wounds
- Letter to Noridian Requesting Withdrawal of Local Coverage Articles on Medicare Coverage of "Amniotic Membrane-Derived Skin Substitutes”