FY 2019 IPPS Final Rule

FY 2019 IPPS Final Rule

August 14, 2018:

CMS has made available its display version of the FY 2019 IPPS Final Rule, which is scheduled to be published on August 17, 2018.

As mentioned in our May newsletter, there were Graduate Medical Education issues included in the IPPS proposed rule.  After considering comments from the public, CMS has revised its proposed rule. Below is a summary of the GME related issues in the final rule.

Medicare GME Affiliated Group 

As you may recall, CMS had proposed to allow new urban teaching hospitals some flexibility in sharing its FTE caps.  The proposed regulation was to allow new urban teaching hospitals to enter into a Medicare GME affiliated group with two (or more) new urban teaching hospitals. This will cause at least one of the new urban teaching hospitals to have a decrease in its FTE cap(s), which was not previously allowed.

CMS included this change in its final rule, but that is not all!  CMS is also allowing any new urban teaching hospital to enter into a Medicare GME affiliated group with an existing teaching hospital(s) and receive a decrease to its FTE caps, as long as the new urban teaching hospital’s caps have been in effect for at least 5 years. An “existing teaching hospital” is a hospital with FTE caps set from the Fiscal Year 1996 cost report. The waiting period for new teaching hospitals to enter into a Medicare affiliated group with an existing teaching hospital is, in essence, 10 years; 5 years of cap building and then an additional 5 years after the caps are effective. This policy goes into effect for newly-entered Medicare GME affiliation agreements entered into beginning July 1, 2019.

Intern and Resident Information System (IRIS) 

CMS had proposed, effective October 1, 2018, to require IRIS data to contain the same total counts of direct GME FTEs and of IME FTEs as the total counts listed on the cost report.  If these totals do not match, the entire cost report will be rejected for lack of supporting documentation. CMS also indicated in the proposed rule that they are in the process of producing a new XML-based IRIS that will capture FTE count data consistent with Medicare cost reporting requirements.