Claiming Foreign Dental Graduates on the IRIS Report
July 24, 2019
In general, a provider cannot claim Direct Graduate Medical Education (DGME) FTEs but can claim Indirect Graduate Medical Education (IME) FTEs for training rotations associated with foreign dental graduates (those students graduating from a dental school not located in the US, Canada or Puerto Rico).
If you have spent time working with the Intern & Resident Information System (IRIS) report, you may know, as a general rule, a resident claimed on the IRIS report should not have its IME FTE greater than its DGME FTE. There is one exception — dental residents.
The federal regulations at 42 CFR § 413.75(d)(6), which apply to the DGME payment, indicates that in order “to include a resident in the FTE count for a particular cost reporting period, the hospital must furnish the following information…If the resident is an FMG, documentation concerning whether the resident has satisfied the requirements of this section.” The requirement referred to are Parts I and II of the Foreign Medical Graduate Examination in the Medical Sciences (FMGEMS) (42 CFR § 413.75(b)).
Conversely, the federal regulations applying to the IME payment, 42 CFR § 412.105, do not list the requirement for FMG’s to have satisfied Part I and Part II of the FMGEMS.
To enter into an approved dental residency program in the United States, the foreign dental graduate is not required to pass Parts I and II of the FMGEMS. Given this, for a foreign dental graduate that is enrolled in a Medicare-approved program, the hospital may be eligible for IME payments but not DGME payments.