Three wound care quality measures are now included on the CMS’ Physician Compare website following a recent update that expanded the quality performance data available.1 We hope this demonstrates an increasing appreciation by CMS of the importance of wound care management.
The CMS launched Physician Compare several years ago to enable patients to make informed decisions when selecting healthcare providers by comparing quality data among physicians. The CMS believes that patients should (and one day, actually will) select institutions and providers on the basis of quality and that the public nature of the data will incentivize clinicians to maximize their performance. In fact, Physician Compare may be one of the best reasons today to participate in quality reporting, because value-driven bonus payments currently are too low to provide incentive.
Although there are many national quality measures available for reporting under the Merit-Based Incentive Payment Program (MIPS),2 the most commonly reported measures are very general (eg, screening for tobacco use). Because wound care is not even recognized as a subspecialty, these most certainly are not wound care specific. Recognizing this, the CMS created Qualified Clinical Data Registries (QCDRs) in 2014. These QCDRs could not only report standard MIPS data, but also develop specialty-specific quality measures to satisfy the reporting requirements of the CMS’ transformational Quality Payment Program (QPP). Nearly every medical specialty launched a QCDR to facilitate MIPS participation and develop quality measures relevant to their patients and practice.
The CMS agreed (after much proactive advocacy) to allow the Alliance of Wound Care Stakeholders to act in lieu of a specialty society, given its role as a convener of all the clinical associations relevant to wound management. We at the US Wound Registry (USWR) and the Alliance got busy vetting and developing relevant quality measures, and in 2014, the CMS approved 14 of our proposed QCDR measures specific to wound management.
The big news today is that, with the recent update, Physician Compare now includes practitioner performance on a selected number of specialty-specific QCDR measures, several of which are these wound care-specific measures. In fact, of the 150+ QCDR measures reported by more than 40 medical specialties, only 11 were chosen for the 2019 Physician Compare update. Three of these are wound care measures. Seven different specialty organization QCDRs are represented, most contributing only one measure. These are large specialties whose QCDRs receive significant industry funding. However, the USWR had the largest number of measures depicted of any QCDR, despite the absence of a medical specialty or any financial support by industry.
The wound care quality measures now depicted on Physician Compare are:
- adequate off-loading of diabetic foot ulcer (DFU) at each treatment visit,
- adequate compression of venous leg ulcers (VLUs) at each treatment visit, and
- vascular assessment of patients with chronic leg ulcers.
Finally, Relevant Quality Data for Patients… and Payment
With the transition to value-based care, quality measure performance is now influencing physician reimbursement rates. Wound care clinicians must participate in the QPP, but they have had to do so with quality measures that were not relevant to wound care practice. A wound care practitioners’ performance on a measure such as “blood pressure control” might be poor—because they do not treat hypertension. The resulting low score on quality performance can reduce a wound care practitioner’s payment rate. Wound care practitioners need wound care-specific quality measures to succeed in the QPP.
The inclusion of wound care quality measures under Physician Compare may signal an emerging emphasis by CMS on the field of wound management. The USWR can already demonstrate that patient care improves when practitioners report data to the USWR. For example:
- Consistent application of adequate compression for VLUs is four times what it was in a decade ago (increasing from 17% of visits to >65% of visits).
- Consistent implementation of DFU off-loading has increased nearly 10-fold (from 6% of visits to nearly 60% of visits).
- Arterial screening of leg ulcer patients has dramatically increased (all examples from CMS performance data, 2015-2017).
We can also show that improved care leads to improved outcomes. Among practitioners reporting the above three measures, VLU and DFU healing rates are 10% higher than practitioners who do not participate in quality reporting.
The prominent inclusion of wound management quality measures within the 2019 Physician Compare update is the result of many years of work by the Alliance and USWR to address the challenges that wound care providers face under the QPP. Although the inclusion is a nice recognition of the value of our measures, we have a long road ahead. Because measure development is funded by only the nominal fees of practitioners who report, we need more clinicians reporting to the USWR.
Additional USWR QCDR measures are being considered for Physician Compare in 2020, including VLU and DFU healing rate measures stratified by the Wound Healing Index. Risk stratification ensures that practitioners caring for the sickest patients do not appear to have worse outcomes than their peers. Honest healing rates are mandatory to demonstrate the impact of advanced therapeutics.
The implications are clear: The Physician Compare website was developed for patients but is increasingly being referenced by payers. The comprehensive downloadable data available on physician performance have been used by payers to determine referral patterns and payment rates. In a value-based world, the only way to keep wound care products, services, and advanced therapeutics on the market, covered by insurance, and sufficiently reimbursed is to demonstrate their value under the QPP. The Alliance-developed USWR wound care quality measures can do just that now that their visibility has been elevated.
1. Centers for Medicare & Medicaid Services. Physician Compare. www.medicare.gov/physiciancompare
. Last accessed October 21, 2019.
2. US Wound Registry. MIPS: The Basics. https://uswoundregistry.com/about-mips
. Last accessed October 21, 2019.