Monday Musings

Last week I outlined the penalties for not participating in PQRS. If you haven’t done it so far, you could be looking at a 6% penalty for 2016 or 2017 depending on whether you attested for Meaningful Use of your EHR, not to mention the “Value Modifier” that will kick in based on PQRS performance.

A total of 255 PQRS measures are available in 2015. You would think there might be at least ONE that had to do with wound care, but there aren’t. Of the 255 measures in PQRS, there are NO measures specific to wound care.  There are 3 PQRS measures relevant to the examination of the diabetic foot  but not the management of diabetic foot In 2015, clinicians need to report 9 measures covering three National Quality Strategy (NQS) domains and one of the nine measures must come from the new “cross-cutting” measure list. You might be able to find 9 measures that meet these criteria from the traditional PQRS list. In addition to the diabetic foot examination measures, you might be able to report Hemoglobin A1C, smoking cessation, medication reconciliation, BMI screening, fall risk (you get the picture). If you can put together 9 measures for which you have sufficient data AND that satisfy the domain requirements, you are all set. However, most wound care providers are going to struggle with this.

Why aren’t there any wound care measures in PQRS? The simple answer is that wound care is not a recognized medical specialty. In 2007 when the AMA’s Physician Consortium for Performance Improvement (PCPI) wanted to have wound care measures developed, they asked the American Society of Plastic Surgeons to develop them. They came up with some reasonable measures, but the 2 selected by CMS for inclusion in PQRS were the 2 “overuse” measures of “not performing saline wet to dry dressings” and “not performing a swab culture of any wound.” Those measures were retired in 2014. I started trying to find a way to get wound care measures into PQRS in 2007. As the Executive Director of the US Wound Registry, I submitted measures during CMS’ open “calls” for measures (don’t bother to do that, by the way) in 2009 and in conjunction with the Alliance of Wound Care Stakeholders in 2011. We suggested measures like compression bandaging of venous leg ulcers and off-loading of diabetic foot ulcers but CMS was not interested. As far as we could tell, CMS refused to consider our suggested measures because they had not been endorsed by the National Quality Forum (NQF). I might add that the wound care measures which had been in PQRS and subsequently retired did NOT have NQF endorsement.

Anyway, the next 3 years were spent trying to understand the process by which measures could get endorsed by the NQF. First you have to wait until the NQF puts out a call for measures in your category (guess what, they don’t have a category for wound care). So, we spent a few years trying to figure out how to get the measures considered when they didn’t fit into the right topics. Then you have to get through the NQF evaluation process. I was informed (nicely) that the randomized, controlled trial data for off-loading and compression wasn’t sufficient to meet their evidence standards. It was also clear that getting even one measure through the NQF process would require more than $200,000. Remembering that we would need multiple measures to keep wound care clinicians from being unable to be reimbursed in the future, it meant we were looking at a $3 million dollar barrier for the future practice of wound care. No matter how much I pleased, no sponsors were stepping up to the plate to financially support the process and after 7 years it was clear that the task was futile I’d actually decided to give it up and just let the industry collapse. Next week I’ll tell you how everything changed around Christmas of 2014.