The Alliance submitted a letter informing Acumen that we cannot support the Non-Pressure Ulcers Episode-Based Cost Measure as currently written and articulating the many reasons the current version does not accurately capture the data necessary for a fair, reliable, accurate measure. The Alliance provided specific recommendations and refinements while emphasizing several key areas of concern, including:

• Costs being attributed to clinicians inappropriately: clinicians being held accountable for the work of other clinicians.
• Costs being attributed to a clinician for care provided in hospitals or facilities not associated with the clinician’s TIN.
• Tests being performed outside of a clinician TIN which they have no control over, yet which are being attributed to them.

As the measure will be considered for potential use in the cost performance category of the Merit-based Incentive Payment System (MIPS), it is important for it to be based on fair, meaningful and correct criteria. The Alliance offered to conduct an educational session on wound care to better inform Acumen’s work on the measure.

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