CMS Letter – Pressure Ulcers (NQF #0678) and Language Modifications

November 15, 2016

Paul Kesselman, DPM, FAPWH Co-chair, Legislative Committee
Cc: Robert Bartlett MD, FAPWHc President,
APWH Steven R Kravitz DPM, FAPWHc, FACFAS Executive Director, APWH

Re: Project Title: Refinement of 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”

The Academy of Physicians in Wound Healing (APWH) has had an opportunity to review and is herein responding to proposed changes regarding the skin lesion currently known as “pressure ulcer”. These are changes terminology of the condition from “pressure ulcer” to “pressure injury”. There’s also a proposed change in the staging system pattern currently using Roman numerals to Arabic numerals.

“Pressure ulcer” and the “Roman Numeral” staging system are used in ICD-10 coding system currently being introduced to the USA while it has been used in Europe and a number of other countries for several years. This is a global system and any attempt to change terminology for the USA will be inconsistent with these world-wide accepted descriptors and related communication. The same can be said for the changes in the staging number system. This has been accepted internationally and allows for international billing and identification of disease states. CMS changing of the term “pressure ulcer” to “pressure injury” would lead to extremely confusing international communication while virtually adding nothing to the understanding of the disease process involved.

Additionally SAWC and a number of other wound care related organizations have raised concern regarding medical legal issues by changing “pressure ulcer” to “pressure injury”. This does not clarify diagnostic criteria while it significantly broadens the language to potentially be inclusive of an extensive number of pathologies many of which would be unintended but could be useful to plaintiff attorneys. The APWH agrees with other organizations that broadening the language in this manner increases plaintiff viability and increases medical legal risk. The potential impact to hospitals and long-term care facilities could be significant aside from that which impacts on physicians and all providers who treat these patients.

In conclusion the issues described herein provide cause for some restraint and therefore the APWH requests that CMS defer any further implementation. In addition, should there be a need to further pursue that proposed we would recommend that a consensus panel be brought together to thoroughly explore any and all potential medico-legal implications.

The APWH would be pleased to meet with CMS, NPUAP and any other interested parties to further assess the proposed changes, the impact they have on patient care, the impact they have on documentation and medical legal aspects of practicing medicine.