Hyperbaric oxygen (HBO) physicians face a MIPS problem that general surgery and internal medicine measure sets were never designed to solve: how do you get fair credit for healing a diabetic foot ulcer in a patient with six comorbidities and a wound that’s been open for six months? The uncomfortable answer is that, for years, you often couldn’t, at least not accurately. This article breaks down which hyperbaric oxygen MIPS measures actually apply to hyperbaric practice, why generic measures misrepresent outcomes, and how a specialty QCDR changes the reporting equation for physicians tired of being scored against the wrong yardstick.
Which MIPS Measures Apply to Hyperbaric Oxygen Providers?
MIPS scores clinicians across four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. Unless a hyperbaric physician qualifies for an exemption, such as falling below the low-volume threshold or participating in an Advanced APM, all four categories factor into the final score that determines a payment adjustment two years later. For the 2026 performance year, Quality and Cost are weighted at 30% each, Promoting Interoperability at 25%, and Improvement Activities at 15%. But those weights get redistributed when a category cannot be scored, and that redistribution is where hyperbaric physicians should pay attention: hospital-based clinicians and small practices routinely have Promoting Interoperability reweighted to zero, which pushes Quality to 55% for most clinicians, or to 40% for small practices with Improvement Activities rising to 30%. For a large share of hyperbaric physicians, then, Quality is not merely one category among four. It is the majority of the score, which makes measure selection within that category the highest-stakes reporting decision a hyperbaric practice makes each performance year.
Here is the structural problem: as of the 2026 performance year, CMS has not published a dedicated specialty measure set for hyperbaric medicine. CMS designates 48 specialty measure sets for 2026. Cardiology has one, with 22 measures. Ophthalmology has one, with 17. Hyperbaric medicine and wound care appear nowhere on the list. That absence has historically forced practices to borrow measures built for general surgery, internal medicine, or podiatry, none of which were designed around chronic wound closure, hyperbaric-specific complications, or the multi-month treatment courses typical of HBO therapy for diabetic foot ulcers, osteoradionecrosis, or compromised flaps.
QCDR measures exist to close that gap. A Qualified Clinical Data Registry can develop measures specific to a clinical population, submit them to CMS for annual approval, and offer them to enrolled providers as MIPS-reportable alternatives to the standard measure set. For wound care and hyperbaric physicians, the US Wound Registry’s CMS-approved measures for 2026 are:
- USWR33: Diabetic Foot Ulcer (DFU) Healing or Closure, risk-stratified by the Wound Healing Index
- USWR34: Venous Leg Ulcer (VLU) Healing or Closure
- USWR36: Pressure Ulcer Healing or Closure (ulcerations not on the lower extremity)
- USWR30: Non-invasive arterial assessment of patients with lower extremity wounds for determination of healing potential
- USWR32: Adequate compression at each visit for patients with VLUs, appropriate to arterial supply
- USWR35: Adequate off-loading of DFUs performed at each visit, appropriate to location of ulcer
- USWR22: Nutritional assessment and intervention plan in patients with wounds and ulcers
- USWR37: Objective measurement of wound surface area with AI-based imaging
Hyperbaric physicians should understand precisely what this list does and does not contain. USWR33 names Undersea and Hyperbaric Medicine among its applicable specialties, so a hyperbaric physician treating diabetic foot ulcers can report a risk-stratified outcome measure written for those patients. What the 2026 set does not contain is a hyperbaric-specific measure. An appropriate-use measure for HBOT in diabetic foot ulcers (CDR8) and a patient-reported outcome measure for late effects of radiation following HBOT (USWR26) were both CMS-approved for the 2023 performance year and are not in the current set. There is no approved measure for hyperbaric adverse events such as central nervous system oxygen toxicity or middle ear barotrauma. The QCDR pathway is the mechanism by which such measures can be developed and approved, and it has produced them before, but a practice planning its 2026 reporting should build around what is approved this year rather than what the mechanism makes possible.
Choosing between the generic MIPS measure set and QCDR-developed measures is the first real decision point for any hyperbaric practice building a reporting strategy, and it shapes everything downstream, from data completeness to how defensible the resulting score looks to a payer or hospital administrator reviewing outcomes.
Why Do Standard MIPS Measures Fall Short for Hyperbaric Physicians?
Most general MIPS quality measures assume a relatively uncomplicated clinical picture: an acute condition, a defined treatment protocol, a predictable path to resolution. Hyperbaric and wound care patients rarely fit that mold. A typical HBO referral involves a patient with diabetes, peripheral arterial disease, chronic kidney disease, and a wound that has already failed months of standard care before hyperbaric therapy even enters the picture. Measures written for other specialties simply were not built to account for that starting point.
This creates a scoring distortion that penalizes exactly the providers doing the hardest clinical work. A hyperbaric center that accepts the sickest, most complex referrals, the cases other practices decline, will show worse raw outcomes than a practice that selectively treats easier wounds, even if the complex-case center delivers superior care relative to what those patients’ conditions predicted. Without risk adjustment, the measure cannot tell the difference between a bad outcome and an expected outcome given the patient’s comorbidities and wound history. That is a critical distinction for any practice trying to demonstrate improved wound healing rates to a hospital system or payer, not just a passing MIPS score.
The numbers make the point. When the US Wound Registry examined twelve months of individual practitioner data, the average DFU healing success rate was 35.7%, with a range from 0% to 100%. Honestly reported healing rates sit well below what most wound care organizations publish, in part because patients who fail to heal are retrospectively reclassified as palliative. A measure that does not risk-stratify cannot distinguish a practitioner treating the severe end of that distribution from one treating the easy end.
A common misconception compounds the problem: many practices assume that reporting any available measure satisfies MIPS obligations equally, as long as the data gets submitted. It does not. A measure poorly matched to a practice’s actual case mix can suppress the quality score even when clinical outcomes are genuinely strong, because the measure was never designed to capture what that practice is actually doing. A wound center reporting a generic postoperative measure, for instance, gains nothing toward demonstrating its actual value: closing chronic wounds in medically complex patients. The measure technically counts toward compliance, but it tells nobody, not CMS, not a payer, not a referring physician, anything meaningful about the quality of hyperbaric care being delivered. Measure selection has to be treated as a clinical and strategic decision, not a box-checking exercise.
How Does a QCDR Change Hyperbaric Oxygen Reporting?
A Qualified Clinical Data Registry operates differently from the standard MIPS measure catalog. Rather than limiting reporting to CMS-published measures, a QCDR can develop its own non-MIPS measures, specific to a clinical specialty, and submit them to CMS each year for approval. Once approved, enrolled physicians can report those measures instead of, or alongside, standard MIPS options. For hyperbaric medicine, this is the mechanism that allows outcome measures like risk-stratified wound closure rate to count toward a MIPS score, and the mechanism through which hyperbaric-specific measures have been approved in the past and can be again.
Risk adjustment is the feature that makes those measures usable for comparison, not just for compliance. USWR33 carries a CMS risk-adjusted designation and stratifies DFU outcomes by the Wound Healing Index, a validated model built from both patient and wound variables, including wound size, wound duration, and comorbidity burden. A practice treating complex referrals can therefore be evaluated against realistic expectations rather than against a flat benchmark built for simpler cases. That matters twice over: it protects the MIPS score of practices doing legitimately difficult work, and it produces chronic wound outcomes data credible enough to show a hospital administrator, a payer medical director, or a referring physician group evaluating where to send patients.
US Wound & Podiatry Registries develops and maintains QCDR measures for wound care and podiatry, developed in conjunction with the Alliance of Wound Care Stakeholders, the Undersea and Hyperbaric Medical Society, and the American Podiatric Medical Association, rather than asking practices to adapt borrowed measures from unrelated specialties. That specialty focus is the difference between a measure set that happens to be technically reportable and one that actually reflects the patients hyperbaric physicians treat. For administrators overseeing multiple wound center sites, it also means roster-wide data that holds up under scrutiny, whether that scrutiny comes from CMS, a MAC medical director, or an internal quality committee asking hard questions about outcomes.
What Are the MIPS Reporting Requirements for Hyperbaric Practices?
CMS sets data completeness thresholds, category weights, and performance thresholds annually, and these figures shift from one performance year to the next. For 2026, the data completeness requirement is 75% and the performance threshold is 75 points, which CMS has finalized at that level through the 2028 performance year. Falling below 75 points exposes a clinician to a negative payment adjustment of up to 9%. Practices should still confirm the current performance year’s specific thresholds and reporting window directly through CMS’s Quality Payment Program resources or their QCDR vendor before finalizing a reporting strategy. Building a plan around last year’s numbers is a common and avoidable error.
Not every hyperbaric physician is required to report at all. Clinicians who fall below the low-volume threshold, based on allowed charges, patient count, or covered professional services, may qualify for an exemption. Certain hospital-based clinicians and those participating in eligible Advanced APMs may also face different scoring rules. These eligibility determinations are made annually, so a practice that was exempt one year is not necessarily exempt the next, and this is worth verifying at the start of each performance year rather than assuming continuity.
Practices should also decide deliberately between traditional MIPS and a MIPS Value Pathway. MVPs remain optional for 2026, with 27 now available, and USWR33 is specified as reportable through either pathway. One 2026 change matters operationally for larger organizations: multispecialty groups can no longer register and report an MVP at the group level and must instead report at the subgroup, individual, or APM Entity level. A wound center sitting inside a multispecialty TIN needs to know that before registration, not after.
The general reporting cycle follows a predictable shape: performance data is collected across the calendar year, and the submission window closes in the spring following the performance year. For the 2026 performance year, submissions are due by March 31, 2027, and there is no late-submission option. Practices working with a QCDR generally do not submit data to CMS directly. The registry vendor aggregates the practice’s data across the enrollment period and handles CMS submission on the practice’s behalf, which removes a substantial administrative burden from clinical staff already stretched thin with charting and patient care. For a solo hyperbaric physician or a small wound center without a dedicated quality reporting staff member, this delegation is often the difference between reporting well and not reporting at all.
How Can Wound Centers Avoid Common MIPS Reporting Mistakes?
Double data entry is the most persistent and preventable source of lost MIPS credit. When staff document a hyperbaric treatment or wound assessment in the EHR and then separately re-enter data for CMS reporting, measures get missed, deadlines slip, and clinical staff burn hours on redundant administrative work instead of patient care. A QCDR that connects directly to a practice’s EHR eliminates that redundancy by pulling structured wound care data from documentation that already exists, rather than requiring a second manual submission process.
Measure selection driven by ease of reporting rather than clinical relevance is a subtler but equally damaging mistake. It is tempting to choose whichever measures require the least documentation effort. But a practice that optimizes for reporting ease over clinical fit ends up technically compliant and strategically empty-handed: the MIPS score exists, but it tells administrators, payers, and referring physicians nothing persuasive about the practice’s actual outcomes. When a hospital quality committee or a payer contract negotiation asks what the wound center’s data actually shows, “we avoided a penalty” is a much weaker position than “our risk-adjusted wound closure rates outperform expected benchmarks for this patient population.”
For multi-site wound center groups, inconsistency across locations is its own liability. If one site reports different measures, uses different documentation habits, or applies risk adjustment inconsistently compared to another site in the same organization, the resulting roster-wide score loses credibility, and so does any comparative claim the organization tries to make internally or externally. Standardizing measure selection and data capture protocols across every site, ideally through a single QCDR platform rather than site-by-site improvisation, protects both the aggregate MIPS score and the organization’s ability to defend its reimbursement and outcomes data under audit or payer review.
Choosing a Measure Set That Matches Your Patient Population
The takeaway is straightforward: hyperbaric physicians who rely on generic MIPS measures are being scored against a yardstick built for a different patient population, and that mismatch has real consequences for reimbursement, for administrative credibility, and for the story the data tells about the specialty as a whole. The next step is evaluating whether a wound care and podiatry QCDR can replace those ill-fitting measures with risk-stratified ones built specifically for chronic wounds. That evaluation is worth doing before the next reporting deadline, not after a score comes back lower than the clinical outcomes deserve.
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