The Alliance submitted to CMS’ request for information on new directions for the CMMI after convening many conference calls with members to determine issues of importance. Comments focused on opportunities within specialty physician models, program integrity, and benefit design/price transparency. The Alliance focused on the growing importance of real-world evidence and patient registry data. Comments spoke once again to the importance of developing quality measures that are more relevant to wound care and pointed again to the relevance of HCPCS coding reform to the CMMI’s focus on improved payment models – given the correlation of coding and payment in practice. Finally, the Alliance highlighted other models for CMMI consideration, including patient accountability models and Voluntary Quality Improvement Reporting Model for Hyperbaric Oxygen Therapy and population management models.

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