The Alliance submitted comments to CMS and the Partnership for Quality Measurement’s Pre-Rulemaking Measure Review Committee reiterating that we do not support the Non-Pressure Ulcers Episode-Based Cost Measure as currently proposed. The letter again articulated our many concerns – which were previously raised in prior comment letters, in meetings with Acumen staff, and most recently as part of our oral statement at the December Pre-Rulemaking Measure Review (PRMR) Listening Session. The Alliance recommended that the measure be withdrawn until further refinements are made and additional testing can be conducted with results provided to the Clinical Expert Workgroup for further discussion.

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