The Alliance presented at the Pre-Rulemaking Measure Review (PRMR) 2024 Measures Under Consideration Clinician Measures Listening Session, reiterating to Acumen and its expert panel that the Alliance does not support the Non-Pressure Ulcers Episode-Based Cost Measure as it is currently written. Similar to our prior letter to Acumen, our statement at the December 17th meeting flagged specific concerns with Acumen’s field testing of the current measure, including: an attribution methodology that incorrectly attributes costs; errors in diagnosis codes and ulcer categories that resulted in the cost for each ulcer category to be incorrectly calculated; and dramatic variations and discrepancies in calculations with no explanations provided. The methodology is so fatally flawed, we emphasized to Acumen in our statement, that the cost measure should not be utilized as it will not only be unsuccessful - it will be detrimental to clinicians.

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