The Alliance submitted comments to CMS’s on its draft policy on Patient Relationship Categories and Codes. Comments noted that the proposed rule puts another burden on the clinician for tracking, coding and documentation but adds no value to patient care, or treatment outcomes. The Alliance emphasized to CMS that currently under MIPS, there are no quality measures that a wound care clinician can report for the actual wound care treatment they perform. As such, the obligatory reporting of quality, resource use, and clinical performance measures may not truly be indicative of neither the wound care work wound care practitioners do nor of the resources that they use to treat their patients. Thus, resource use for any wound care clinician will be skewed until this issue is resolved. The Alliance suggested that the Patient Relationship Categories and Codes rule be delayed at least unto 2018 or beyond to allow clinicians sufficient time to adjust to all the other MACRA and MIPS documentation and reporting changes and challenges.

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