The Alliance submitted comments that overall supported CMS’ efforts to streamline and de-duplicate measures. However, in comments to “Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2019 Rates,” the Alliance noted concerns with some of the provisions directly impacting wound care and, specifically, pressure ulcers. The Alliance recommended that CMS:

• Remove pressure ulcers (PSI 03) from the NQF #5031 Patient Safety and Adverse Events Composite Measure
• Create a stand-alone quality measure for PSI 03, Pressure Ulcer Rates
• Or, as an alternative, increase the weight currently outlined in the proposed rule for pressure ulcers.
• Implement the Equal Measure Weights approach outlined in the proposed rule.

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