FY 2021 IPPS Final Rule: Displaced Resident Policies
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October 22, 2020
CMS has issued the FY 2021 IPPS Final Rule that took effect on October 1, 2020. The proposed rule addressed growing concerns of operational and administrative challenges resulting from residents who transferred or matched to other programs or participate in planned rotations at other hospitals before the official closing date. As a result, CMS has redefined “displaced residents” to allow more flexibility to closing hospitals and residency programs.
After considering comments from the public, CMS has finalized its rule with few changes from its proposed rule. Below is a summary of the GME related issues in the final rule.
Redefining Displaced Residents – CMS finalized the definition of Displaced Residents as those who meet one of the following scenarios:
- Leave a program after the hospital or program closure date is publicly announced, but before the actual closing day;
- Is assigned or training at planned rotations located at another hospital and who is unable to return to their rotation at the closing hospital or program;
- Is accepted into a GME Program at the closing hospital or program but has not yet started training at the closing hospital or program;
- Is physically training at the hospital on the last or next-to-last day of closing program or hospital;
- Is on approved leave at the time of the publicly announced closure, or closing date resulting in a resident who cannot return to their program.
How to Request Temporary GME Cap Increase – CMS also made modifications to the required information that must be submitted to a receiving hospital’s Medicare Administrative Contractor (MAC) to request a temporary GME cap increase:
- The receiving hospital must contact its MAC within 60 days after it starts to train the displaced residents;
- Identify displaced residents who are coming from the closing hospital using only the last 4 digits of the social security number or the NPI of the displaced resident;
- The amount the receiving hospital will exceed its GME caps by training the displaced residents;
- Length of time the adjustment is needed for the resident to complete the residency program.
Training displaced residents from a closing hospital is one of several factors that can help increase a teaching hospital’s likelihood of being awarded redistributed slots. CMS regulations allow temporary GME cap slot transfers to hospitals that accept residents displaced from a closing program.
If operating above the limits, the closing hospital will determine how to disperse available cap slots and may choose against transferring available GME caps slots. Hospitals operating under GME caps are ineligible for GME cap increases to train displaced residents.
Following is a link to the FY 2021 IPPS Final Rule: https://www.govinfo.gov/content/pkg/FR-2020-09-18/pdf/2020-19637.pdf
About the Author:
Sarah Ottesen
626-656-8312
sarah@gmesolutions.com