Quality Assurance Resource Guide: MACRA & MIPS are Fixable Problems for Wound Care Specialists

As I sit here early morning, thinking about my upcoming travel to the Medicare Evidence Development & Coverage Advisory Committee (MEDCAC) meeting in Baltimore this July, I figured out a way to verbalize the pains that we will be going through over the next couple of years as wound care practitioners. It is with great sadness that those of us who do practice effective wound care and management may be at a disadvantage under the new Medicare Access and CHIP [Children’s Health Insurance Program] Reauthorization Act (MACRA). For reasons that are not entirely clear, the Centers for Medicare & Medicaid Services (CMS) has been authorized by Congress to alter the payment model structure for Physician Fee Schedule reimbursement starting in 2016. As a result, MACRA was born. In essence, the “feds” will be slowly carving away the fee-for-service (FFS) model we have grown accustomed to in practice. Beginning this year, CMS plans to cut FFS model payments by 30% and to have approximately 85% of all monies distributed as payments under FFS. By 2018, that number drops to 50%. This is where MACRA turns into the Medicare Incentive Payment System (MIPS). Getting back to MACRA/MIPS, the questions become: Why is the problem so glaring, and how did CMS miss the chance to track venous disease? These are the questions I have the opportunity to address, but the more important problem is: How are wound care specialists supposed to compete in the market as we move toward 2018? The law states payment is “based on comparative data of similar specialty in a geographic area.” So, those family-practice physicians working only in wound care will be scored and vetted against other family-practice physicians, some of whom may not be performing wound care or treating high-risk, high-cost patients.  As a result, these physicians could be subject to a negative reimbursement against one’s peers, simply because CMS does not recognize wound care as a specialty based on the taxonomy identifiers. For wound care specialists, the problem exists on one base level: CMS has not adopted any methodology as of this writing to track and manage patients living with venous disease.  With an annualized cost of almost $18 billion, CMS would want to track venous disease. CMS already tracks diabetic foot ulcers ($245 billion), but venous disease has seemingly slipped through the cracks.  This is why the aforementioned MEDCAC meeting, which literally could be occurring as you’re reading this article, is so vital. In essence, it is at this meeting that these glaring gaps in practice, evidence, and ability to track can be brought to proper attention.  

From an educational perspective, this is where the clinical organizations have the greatest impacts for the groups they represent. I will be among those (including Gary Gibbons, MD, and Peggy Dotson, BS, RN) who have the privilege of representing the Association for Advancement of Wound Care and the opportunity to speak with committee members for purposes of educating them on the need for complete inclusion of the wound care specialist in the payment model for venous disease, including those cases involving endovascular procedures. We will also introduce the need for complete multi-interdisciplinary guidelines that are agreeable to all clinical organizations, as well as explaining the incidence and cost indices of venous disease care. The basis of this meeting is really to “curb” the interventional endovascular procedures. However, there is a larger opportunity for those individuals, like myself, who will be present. In the past, a majority of these meetings have been designed and presented by various organizations to “protect the turf.” In this case, the lessons learned from the peripheral artery disease MEDCAC meeting in September 2015 have brought forth a more collegial environment. For the first time, clinical organizations are communicating to one another and sharing their presentations to help make the arguments more coalescing to the committee. This shared “one voice” approach is how clinicians will be able to overcome CMS and the bureaucracy that creates the issues we are forced to live with and practice within. The challenge is to get CMS to accept the need to track venous disease and appropriately understand how to include wound care specialists in the new MIPS. I hope we are successful, and that even just a few of us can make a difference for our specialty group as a whole. 

Eric J. Lullove, is medical director at West Boca Center for Wound Healing, Boca Raton, FL; owner of Laser Love Med Spa, Boca Raton; healthcare policy committee, Association for the Advancement of Wound Care (AAWC); AAWC liaison, Alliance for Wound Care Stakeholders; consultant, Hollister Wound Care, Libertyville, IL, Medline Industries Inc., Mundelein, IL, Osiris Therapeutics, Columbia, MD, Human Regenerative Technologies, Redondo Beach, CA, and Cumberland Pharmaceuticals, Nashville, TN.