Increasing Audits of GME Hospitals
November 14, 2018 The Office of Inspector General (OIG) issued a report titled “CMS Did Not Always Ensure Hospitals Complied With Medicare Reimbursement Requirements For Graduate Medical Education”. Said report was based on OIG audits, which found that hospitals in six Medicare Administrative Contractors (MAC) jurisdictions counted residents (including interns) as more than one full-time...Read More
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Incorrect FTE Reporting Could Penalize Your Hospital
October 16, 2018 September’s newsletter provided a breakdown of the Intern and Resident Information System (IRIS) report. This newsletter will focus on one of the most important stats in the IRIS Report — the initial residency program. The initial residency program is important because it generates the initial residency period, which we will refer to as the “IRP”. Since most hospitals are...Read More
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IRIS Reporting Breakdown
September 19, 2018: Academic medical centers are required to submit to Medicare their Intern and Resident Information System (IRIS) report with their yearly cost report filing. The IRIS report is used to calculate the amount of reimbursement the hospital will receive for the direct and indirect costs of the Graduate Medical Education programs. The IRIS report contains information regarding...Read More
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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...Read More
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Good News for GME Reimbursements — Saint Francis Medical Center v. Azar Decision
August 1, 2018: On June 29, 2018, in the D.C. Circuit Court of Appeals, a significant victory in a Medicare reimbursement appeal was obtained. This case involved 277 hospitals seeking to challenge various payment decisions spanning the last two decades. The providers were contesting so-called “predicated facts” (factual determinations relevant to the payment year at issue, but were made in...Read More
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HRSA’s Response on The Establishment of the CHGME Quality Bonus System
July 2, 2018: Before we lose the interest of the non-children’s teaching hospitals, we would like to note, it may be wise to keep any changes in the CHGME funding in your sights; if successful, we do not see a reason why the Medicare GME Program couldn’t follow suit. In the June 26, 2018 Federal Register 1, the Health Resources and Services Administration (HRSA) issued a final response to its...Read More
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Medicare Approved Programs
June 13, 2018: Congress decided Medicare should pay its share in training our future doctors, at least until the communities were ready to support the programs; over 50 years later, Medicare is still paying its share in the direct and indirect costs for graduate medical education. The rules surrounding this payment are quite complex. In this article, we will be discussing the regulations...Read More
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CMS Ruling 1727-R: Jurisdiction of the PRRB Over Appeals Challenging a Regulation
May 9, 2018: As a result of the U.S. District Court for the District of Columbia’s holding of Banner Heart Hospital v. Burwell, 201 F. Supp. 3d 131 (D.D.C. 2016), CMS issued a favorable ruling for providers on April 23, 2018. CMS Ruling 1727-R states that “for appeals of cost reporting periods that ended on or after December 31, 2008 and began before January 1, 2016 that were pending or filed...Read More
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FY 2019 IPPS Proposed Rule
May 1, 2018: CMS has made available its display version of the FY 2019 IPPS Proposed Rule, which is scheduled to be published on May 7, 2018. There are two Graduate Medical Education issues that we would like to highlight. Medicare GME Affiliated Group First, CMS is proposing to allow new urban teaching hospitals (i.e. hospitals that did not have residents in their FY 1996 cost reports) some...Read More
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Academic Medical Centers Can Be Paid for Non-Accredited Training Programs
May 1, 2018: Are you skeptical? Certainly the fiscal intermediary’s auditors are and also current CMS Hospital Payment Policy Staff have confused the matter. But, have heart and claim the costs. Here’s why! My analysis always begins with evaluating the intent of the Medicare Law. On this issue, the law clearly states that Medicare will share the Hospital’s cost of training. During my tenure...Read More
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