CMS recently announced that the Total Per Capita Cost (TPCC) cost measure is now open for comment. CMS (through its contractor, Acumen) is gathering comments on the TPCC measure to determine updates to the measure’s attribution methodology (“attribution” is the process of determining which physicians gets blamed for a patient’s Medicare cost). Acumen is inviting feedback. Although that’s not why I am posting this blog – here’s the link to the online survey now through 11:59 PM ET on May 17, 2024.

I am posting this because it has to do with “attribution” of total Medicare costs by specialty. In 2019, I posted a blog explaining that as a Family Practice doctor, I was held accountable for the total per capita cost (TPCC) of my wound center patients, because CMS assumed that I was their primary care doctor. As soon as Undersea and Hyperbaric Medicine got a specialty code, I changed my specialty code so that CMS understood I was practicing UHM (there’s no wound care specialty, so there is no specialty code). Although I am board certified in UHM, there is no federal requirement that a physician must be board certified in the specialty they designate.

Here is the point: If your specialty is designated as Undersea and Hyperbaric Medicine (UHM), you are exempted from the TPCC measure. That means you can’t be “blamed” for the annual costs of a patient’s care. However, if you are a Family Practice doctor or a Nurse Practitioner who manages wound care patients, you are included in the TPCC cost measure. See screen captures from the CMS files about which specialties are included and excluded. I highlighted a few.

I know how irrelevant this all seems, but the financial future of wound care as a field could rest on whether the various individuals who practice wound management will be held accountable for global patient costs that they can’t control. This all stems from wound care NOT being a specialty. (And while I can’t give anyone advice, if I was on the list of practitioners who are included in the TPCC cost measure, and I was practicing full time wound care, I’d consider changing my specialty code to UHM, the description of which does include wound care.)