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.  

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