The Alliance submitted comments to CMS on MACRA Episode Groups. In its comments, the Alliance reported that chronic wounds and ulcers are reaching epidemic proportions in the United States. Despite their prevalence, this problem remains off the CMS radar screen even though Medicare will devote at least $30 billion dollars to their treatment this year (and by some estimates, twice that amount). The Alliance urged CMS to create episodes of care around the following high resource use conditions:

• Diabetic foot ulcers
• Venous stasis ulcers
• Stage 3 and 4 pressure ulcers

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