Last year, on behalf of its members, the APWCA submitted comments to CMS regarding the electronic clinical quality measure titled, “Hospital Harm – Hospital- Acquired Pressure Injury.” We expressed concern that the denominator had no exclusions and suggested that certain exclusions be included. A cope of that letter is below:

The American Professional Wound Care Association® (APWCA) is a non-profit medical association welcoming medical providers from all disciplines involved in prevention and treatment of difficult wounds. Through a synergy of disciplines, APWCA has been a worldwide leader in clinician advocacy and education for the prevention and treatment of acute and chronic wounds since 2001. This association provides an informational and educational forum for healthcare providers, while promoting excellence in wound healing and patient advocacy.

On behalf of the APWCA we appreciate the opportunity to comment on the electronic clinical quality measure titled, “Hospital Harm – Hospital- Acquired Pressure Injury.” We are concerned that the denominator has no exclusions. All hospitalized patients ages 18 years and older are included. We agree that pressure ulcers should be avoided in all patients when possible, but contend that all pressure injuries are not preventable. We agree with your statement in question #7 that “practices may change for end- of-life or hospice patients who have a comfort care-only order.” Comfort care-only orders can be captured in some EHR systems, but not all. There are also some hospitals still not using a fully functional EHR. Therefore, we do suggest denominator exclusions in this measure.

We suggest that the following exclusions be considered:
Palliative care
End of life care
Metastatic malignancies
Septic shock

As you know, the same critical pathologies that compromise perfusion to critical organs such as the heart, lungs, and brain also compromise perfusion to the skin!

Thank you for the opportunity to provide this feedback and for considering our suggestion

Robert Skerker, MD, FAPWCA
Medical Director, Morristown Wound Healing Center
APWCA liaison to the Alliance of Wound Care Stakeholders

Jeffrey D Lehrman, DPM, FASPS, MAPWCA
Medical Director, Center for Wound Healing and Hyperbaric Medicine at
Crozer-Chester Medical Center
APWCA Board of Directors