Pearls on the Foundations of MIPS in Wound Care

© 2025 HMP Global. All Rights Reserved.
Any views and opinions expressed are those of the author(s) and/or participants and do not necessarily reflect the views, policy, or position of Today’s Wound Clinic or HMP Global, their employees, and affiliates.

Transcript

Hi, I'm Dr. Caroline Fife. I'm the Chief Medical Officer of Intellicure, LLC, and also a professor of geriatrics at Baylor College of Medicine in Houston. And I've been a wound care practitioner for more than 30 years now, which is a painful thing for me to think about!

MIPS performance is evaluated across several categories. Can you walk us through the key metrics for wound care providers as they pursue reporting this year?

If you look at the 300 or so Quality Measures, and I just want to talk about Quality because the other things, the other categories are just harder to have a conversation about, Quality at least is something people can kind of grasp on to. If you just look at the Quality piece, there are about 300 Quality Measures that are approved for 2024 and you can go on the CMS website and look at all those different Quality Measures, the vast majority of them have nothing to do with wound care. You can see that the majority of them are really targeting primary care. So that means that there's a very narrow list of Quality Measures that wound care practitioners could even realistically ever have data for, not to mention whether or not they are relevant.

And I'll give you some examples. BMI, obtaining a BMI on patients—always a good thing to do. You could argue that it's not very specific to the provision of wound care. Asking patients to smoke and counseling smokers to stop smoking—always a good thing to do but you could argue that it's not really directly related to the quality of wound care. Recording an A1C in the chart for all diabetics—another very important thing to do, and by the way, something that would be required if you ever get audited by Medicare for your use of skin subs or for hyperbaric oxygen therapy, they're gonna wanna see that you have recorded an A1C. But you could argue that that's not even the best way to measure wound care.

There are two that are somewhat close to wound care. Remember, we're just talking about Quality Measures. Two that were created by the American Podiatric Medical [Association]. One is in all diabetic patients evaluating those patients for peripheral neuropathy. The little fine print around that is that patients who are known to have peripheral neuropathy are excluded from the measure. And you could argue that every patient who has a diabetic foot ulcer, if you're a wound care doc, probably ends up being excluded from the measure since almost all of those have neuropathy and you know it. But the peripheral neuropathy check for diabetics is probably the closest thing to being relevant.

And the other is in patients who have diabetes making sure that they have appropriate footwear. So those are the two that—they're MIPS 126 and MIPS 127. Those are the two that probably have the closest relevance to us. The others that that may be reportable for wound care practitioners tend to be documentation of the medications in the medical record and doing a fall plan of care.
So there end up being about eight quality measures that realistically a wound care doc could report on and I'm not suggesting it's limited to this. I'm just gonna throw out there are the ones that tend to get the attention from a national standpoint are recording—and it's not just recording an A1C in diabetics, you have to record the A1C into past the measure. It has to be less than 9. That's a tall order for most patients with a diabetic foot ulcer since they tend to get diabetic foot ulcers because their glucose is not well controlled. But that's MIPS number 1. Making sure patients have an advanced care plan. That's MIPS 47. That's a common one. Screening for high blood pressure and following up, documenting that there's a follow-up in place for high blood pressure, MIPS 317, that's a common one. The tobacco screening one I mentioned, which is MIPS 226, the diabetic foot measures from the APMA 126 and 127, meds is MIPS 130 and the fall plan of care is MIPS 155.

So those are, that's kind of the basic ones. You have to have at least six. So there are eight that may be useful for wound care practitioners. That's the major answer.

If you'll let me keep babbling, there's some fine print. And the fine print is that Medicare in 2014 began to allow medical specialty societies and other organizations to develop Quality Measures that were relevant to specialties that got left behind. And so my company, Intellicure, created a nonprofit entity called the US Wound Registry because there wasn't a physician specialty society. We just decided to do that for the good of the field. And we again to develop Quality Measures through our nonprofit organization and CMS has approved a suite of about six Quality Measures. I can provide information about what those quality measures are. They're hard to report, though, because electronic health records don't like to incorporate any Quality Measure programming that they don't have to do.

But there are some Quality Measures that are relevant to wound care. They're just very tricky for clinicians to report, but they're not rocket science. It's recording diabetic foot ulcer, offloading, getting patients with a venous ulcer, inadequate compression, making sure patients with a wound or an ulcer on the lower extremity have had arterial screening, doing a nutritional screen. Those are the big ones that are relevant to wound care but the likelihood that a wound care practitioner could get those in their EHR is really difficult.

How do practices report these Quality Measures?

Super important. Of course, it kind of depends on your practice setting in a way you know until recently most clinicians that did wound care full-time or part-time even, were in hospital-based outpatient departments. That is where I've spent my career. But there's a real sea change happening in wound care where more and more clinicians are office-based, more and more wound care practitioners are office-based. For docs that are working in hospital-based outpatient departments, they may be below the reporting threshold because that payment rates in the HOPD are different than they are in the office-based setting.

But as we see this trend towards office-based practice, MIPS becomes relevant because what I didn't say before is that if you totally ignore, if you're required to purchase a page in MIPS remaining eligible, which means you have to do it, and you ignore it, you can lose up to 9% of your Medicare billing. It takes two years for those penalties to hit. So if you get a penalty from your reporting in 2022, you feel it in 2024. It's also possible to get bonuses, but the bonuses are tiny. Even when you do fantastic, most of the bonuses have been less than 2% of your Medicare billing.

But the point is there's a lot of money at risk. And how you report in part is determined by your practice setting. I am always a little surprised to learn there are lots of doctors in private practice that still use paper. So for those docs that still don't have an EHR and they're actually filling out charts on paper, it's getting trickier. It is possible to report some quality measures using claims, but that claim system is beginning to be phased out. It's not gone yet. It's assumed that most clinicians nowadays are gonna have an electronic health record, and that's where it's really important for a physician, especially in the office setting, to make sure that the EHR they're using. It's the programmatic specifications for Quality Measures every year because if, for example, Medicare changes the specifications for what the blood pressure is that is going to be considered high and your EHR has old specifications, you could fail a measure just because the specs aren't up to date. Lots of doctors don't know that they have to ask their EHR to make sure that the specifications are updated.

All that to say, there are some measures that can be reported directly from an EHR, but it's very hard to do that. You've got to be pretty tech savvy. It's a good deal for primary care docs. Probably not very many wound care docs or podiatrists are going to want to do the direct EHR measures. So what would happen is you'd be recording information inside your EHR and then when it comes time to get that information to CMS you would usually work with a registry. And there are registries that their full-time job is to help extract data from an electronic health record and send the calculations onto Medicare for your final scoring.

So most clinicians have had the experience at this point of having connected with some kind of a registry and that would be the typical thing and there are lots of them out there. You can just Google these registries and you'll find out what your choices are and your EHR vendor may be able to suggest some specific vendors of these registries that tend to work with their EHR. If that is a helpful answer on how you report. It's primarily going to be one way or another through your EHR and possibly with the help of a registry.