I’ve got some good news and some bad news.
First, the Good News
CMS (the Centers for Medicare and Medicaid Services) has approved 9 wound-care and hyperbaric medicine relevant quality measures for the 2022 reporting year. The quality measures were developed jointly by the US Wound Registry (USWR) and the Alliance of Wound Care Stakeholders. You can view the details here: https://uswoundregistry.com/quality-measures/.
|USWR29||Adequate Off-loading of DFU at each visit|
|USWR32||Adequate Compression of VLUs at each visit|
|USWR30||Non Invasive Arterial Assessment of patients with lower extremity wounds or ulcers for determination of healing potential|
|CDR6||VLU Healing or Closure|
|DR2||DFU Healing or Closure|
|USWR31||Non-lower Extremity Pressure Ulcer (PU) Healing or Closure|
|USWR22||Patient Reported Nutritional Assessment and Intervention Plan in Patients with Wounds and Ulcers|
|USWR26||Patient Reported Outcome of late effects of radiation symptoms following treatment with Hyperbaric Oxygen Therapy (HBOT)|
Now for the Bad News:
This year, CMS decided to reject the VLU compression measure and it was only my pleading that saved it for one more year. Why? Is it because CMS doesn’t believe that compression is needed for VLUs? No, it’s because not enough wound care practitioners report the VLU quality measure, so CMS assumes that we don’t need it. In fact, CMS is not convinced we need ANY quality measures for wound care. Truthfully, there are some days I think that CMS might be right. For one thing, no one really cares about MIPS. You work hard to achieve a good score with all the components of MIPS (and the effort is not trivial) just so that you can get a bonus of than 2% of your Medicare Fee for Service (FSS) payments. Why bother?
However, the main reason for the low utilization of wound care quality measures is that it’s hard to report them because, despite our considerable efforts, electronic health record (EHR) vendors didn’t want to go to incorporate the wound care measure specifications into their EHRs in order to enable reporting. Most doctors who do participate in MIPS haven’t worried about using specialty specific measures because they could come up with 6 standard MIPS measures from their data. However, this year there is more bad news – many of the standard MIPS measures that wound care doctors have relied on won’t be counted by Medicare this year (e.g. Hgb A1c, BMI measurement and screening, etc.). In other words, in 2022, wound care practitioners are not going to have enough standard MIPS measures. In 2022, it will be hard for a wound care or hyperbaric medicine practitioner to participate in MIPS without using quality measures relevant to the field.
Losing all the wound-care and hyperbaric quality measures may not seem like a problem. However, Medicare is gradually moving towards requiring that practitioners report “specialty specific” measure sets. That would mean that every wound care practitioner would have to report the quality measures relevant to their primary specialty. I am board certified in family practice but since I don’t do breast cancer or colon screening, I won’t be able to pass the measure set chosen for FP. Right now that won’t hurt me financially, but if CMS continues down the path of the Quality Payment Program, in the near future, I won’t be able to practice without participation in MIPS and I won’t be able to participate in MIPS without wound care relevant quality measures.
There is some good on the topic of overcoming barriers to reporting wound care quality measures. I will talk about that next time.