Urgent: Your Input Needed

In April 2016, the NPUAP (National Pressure Ulcer Advisory Panel) announced changes to the pressure ulcer staging system after holding a consensus conference.  

Most significantly, they decided to change the term "ulcer" to the term "injury".  The link to the NPUAP changes is in the brief that is attached.  There have been multiple articles on the proposed changes and there are articles in press currently which refute the decision making that lead to these changes.

The AAWC Board of Directors released a position statement on these changes in October 2016 and opposes moving forward with the proposed revision at this time. See the position statement here.

The proposed new language does not accurately reflect current research and knowledge on the pathophysiology of pressure induced tissue damage.  There are currently no ICD10 codes for a pressure injury and changing the terms would mean moving the ulcer codes into the TRAUMA chapter.  In addition, the medicolegal implications of terming these as "injuries" will surely negatively impact patient care and providers.

There are 2 sets of public comments which are currently open. CMS and the NQF are actively evaluating a change to their language but are seeking public comment first.

Public comments are due November 17 on a cross-setting post-acute care measure under the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) to further develop and refine the percent of residents or patients with pressure ulcers that are new or worsened (short-stay) (NQF #0678) and language modifications being explored with the term “Pressure Injury”. CMS seeks feedback on potential updates to measure specifications and items used to calculate the quality measure. Visit thePublic Comment webpage for more information.

Specifically, here is the what they want on the new terminology:

• CMS is also soliciting comments on changes in terminology for the pressure ulcer measure specifications and assessment items. NPUAP revised the Pressure Injury Staging System following a consensus conference in April 2016. The NPUAP replaced the term “pressure ulcer” with the term “pressure injury” stating the “change in terminology more accurately describes pressure injuries to both intact and ulcerated skin.”¹ New NPUAP guidance further clarified that “in the previous staging system Stage 1 and Deep Tissue Injury described injured intact skin, while the other stages described open ulcers. This led to confusion because the definitions for each of the stages referred to the injuries as ‘pressure ulcers’.” CMS is soliciting comments regarding the adoption of new terminology as espoused by NPUAP.

Comments should be submitted here:   PressureUlcerPublicComments@r ti.org 

The NPUAP have already contacted the NQF and started the process of having the terminology changed in quality measures. 

Project Specific Instructions

1. Do not include personal health information in your comments.
2. If you are providing comments on behalf of an organization, include the organization’s name and your contact information.
3. If you are commenting as an individual, submit identifying or contact information.
4. Please indicate which setting you are providing comments on. You may submit general comments on all four post-acute care settings, or you may provide comments specific to individual settings.
5. Send your comments to TOHPublicComments@rti.org, Comments are due by December 11, 2016.