Do Leave of Absences Impact Medicare GME Reimbursements?
December 11, 2019
Medicare Graduate Medical Education (GME) regulations have many exceptions and special circumstances hospitals must consider when filing their Medicare cost reports. One special circumstance is when a resident takes a leave of absence.
As explained in IRIS Reporting Breakdown, teaching hospitals are required to submit their Intern and Resident Information System (IRIS) report with their yearly cost report filing. In the IRIS report, all eligible resident training assignments are reported. Does a resident’s leave of absence qualify as an eligible assignment and should it be included in the IRIS report?
Medicare Regulations allow leave of absences to be counted on the IRIS report regardless if the leave of absence was paid or unpaid time off, as long as it does not prolong the total time of the resident’s training (42 CFR § 413.79(h)).
What to Include on the IRIS Report
If a resident is required to make up part of a leave of absence, the hospital can claim the days during this absence that do not have to be made up.
If a resident is required to make up part of a leave of absence, consider the following example:
Dr. Renee Smith
- Program: Internal Medicine
- Length of Program: 3 Years
- Date of Enrollment: 7/1/2016
- Expected Completion Date: 6/30/2019
- Leave of Absence: 3/1/2019-5/31/2019
- Extended Training: 7/20/2019 (extended 20 days)
Instead of completing the Internal Medicine training on 6/30/2019, Dr. Smith had to complete an additional 20 days, therefore she completed her training on 7/20/2019. When reporting this time on the IRIS report, the portion of the leave of absence the hospital would claim is 3/1/2019-5/11/2019; while 5/12/2019-5/31/2019 will be left unclaimed. Once Dr. Smith returns from her leave, depending on the type of training and location of training, the hospital may be eligible to claim the training from 6/1/2019-7/20/2019.
One missed FTE can impact the hospital’s Medicare GME Payment significantly. Knowing how to claim special circumstances, such as leave of absences, are vital to your hospital’s Medicare GME Reimbursement.