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Here We Go Again: CMS is Testing a New “Non-Pressure Ulcer” Cost Measure

by | Jan 26, 2026 | Field Test Report | 0 comments

Here We Go Again: CMS is Testing a New “Non-Pressure Ulcer” Cost Measure

First in an Ongoing Series About the Field Test

I have been longing to think about something other than CTPs/skin subs, but believe me that another attempt by CMS to create a “non-pressure ulcer” cost measure was not what I wanted to think about. This subject is a great way to decrease interest in a person’s social media presence, but it can’t be helped.

Here’s my attempt at a “CliffsNotes” version of the topic:

  • Every advanced practitioner who submits Medicare claims is somehow participating in the Quality Payment Program (QPP).
    • Some of you are in Accountable Care Organizations, but many/most are under the Merit Based Incentive Payment Program (MIPS).
  • Each practitioner’s MIPS score is calculated from 4 weighted categories: Quality, Improvement Activities, Promoting Interoperability (previously “meaningful use of the EHR”), and Cost.
    • The final MIPS score determines whether a practitioner gets as much as a 9% cut to their Medicare payments, no change, or a small bonus.
  • Cost is calculated by the Centers for Medicare and Medicaid Services (CMS) via a complex formula that is very hard for anyone to understand but is developed with input from an expert workgroup.
  • CMS has been methodically selecting specific high cost services and creating “cost measures” in a variety of specialties.
    • CMS evaluates the total Medicare cost of caring for patients with various conditions over a defined episode of care. The goal is to determine whether patients under your care for a specific disease or condition cost more or less than patients treated by your “peers”.
    • If CMS determines that your patients’ cost more than they should, they can clawback some of your Medicare payments.
  • Because 30% of a practitioner’s final MIPS score is based on CMS’s calculation of your cost, it is possible to perform well in the other 3 MIPS categories, but still get a cut to your Medicare payment based on poor “performance” with the Cost measure.
  • In 2024, CMS (using the contractor, Acumen) tried to develop a cost measure for “non-pressure ulcers” (meaning, diabetic foot ulcers, venous leg ulcers, arterial ulcers and generic “chronic ulcers” – any ulcer that is NOT a pressure ulcer).
  • New cost measures are first “tested” by analyzing claims from physicians and then posting the “Field Test Report” on the CMS portal where QPP information is available to each practitioner.
  • The 2024 Field test showed serious flaws which wrongly attributed the costs of Medicare patients.
  • CMS did not adopt this seriously flawed cost measure thanks to the advocacy of the Alliance of Wound Care Stakeholders, the APMA, and you.
  • In 2026, CMS/Acumen are testing a new non-pressure ulcer cost measure.
  • The only way we will find out if this measure has serious flaws is for practitioners to download their Field Test report when they become available after January 29th.

I will be posting a series of blogs explaining this in more painful detail, including a step by step guide of how you can download your Field Test report.

(And yes, those practitioners’ who spent too much money on CTPs/skin subs in 2024 could cause unsuspecting practitioners to get a Medicare cut – I will tell you how that nearly happened to me in a future blog.)

Additional Resources:

The posts below were created for the previous field test report in 2024. The information below will put the new report in context. Some details will have changed for the 2026 report:

The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.

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