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  • Washington Highlights

    AAMC Submits Comments on GME Proposal in FY 2022 IPPS Proposed Rule


    Brad Cunningham, Sr. Regulatory Analyst, Graduate Medical Education

    The AAMC provided comments to the Centers for Medicare and Medicaid Services (CMS) regarding the graduate medical education (GME) portions in the proposed fiscal year (FY) 2022 Inpatient Prospective Payment System (IPPS) rule.

    The rule included CMS’s proposals to implement the distribution of 1,000 new residency slots and other provisions related to Medicare’s payments for GME that were enacted as part of the Consolidated Appropriations Act, 2021 (CAA, P.L. 116-260) [refer to Washington Highlights, April 30]. The AAMC also submitted comments regarding hospital payment — including changes to organ acquisition costs and changes in hospital quality programs — and a response to a request for information on health equity [refer to related story].

    Below are highlights of the AAMC’s comments regarding GME:

    • The AAMC Urges CMS to Make Significant Changes to the Proposal Regarding Distribution of 1,000 New Medicare Funded GME Slots:  CMS solicits comments on two alternative methodologies for awarding 1,000 new GME slots, distributed 200 per year over the next five years, provided by Section 126 of the CAA. For both distribution methods, CMS has proposed limiting awards to 1.0 Full-Time Equivalent (FTE) per qualified hospital that applies per year and to prorate (or distribute less than 1.0 FTE) in the event of a tie. The first distribution method ranks hospitals based on a Health Professional Shortage Area (HPSA) score; qualified hospitals with the highest HPSA score will be awarded a slot. CMS will then award any additional slots to hospitals with the next highest HPSA score and so on until all slots are distributed.

      The second distribution methodology would be only for FY 2023 and will allow CMS to work with stakeholders to develop a distribution methodology for FY 2024 and beyond. In the second distribution alternative, priority would go to hospitals that meet all four criteria for a “Qualifying Hospital.” Subsequently, CMS would distribute awards to hospitals that meet three categories if slots remain — then they would move to those that meet two categories, and then finally to those that meet one category. For either distribution method, a tie would occur if there are more qualified hospitals in a distribution priority than available slots. 

      The AAMC urges CMS to adopt the second distribution methodology, with modification, for FY 2023 alone. Further, the AAMC urges CMS not to limit award distributions to 1.0 FTE per hospital, per year, nor distribute less than 1.0 FTE in the event of a tie. The AAMC also urges CMS to expand the definition of Category 4 hospitals — or hospitals that serve HPSAs — to include hospitals located near but not geographically within an HPSA boundary. 
    • Updates to Rural Training Tracks (RTTs): CMS has proposed several revisions to the RTT program to allow: RTT cap adjustments for both urban and rural RTT participants; any accredited training program to participate in an RTT; and hospitals to participate in more than one RTT, with an RTT cap adjustment for any new subsequent RTT established beyond the first. The AAMC supports the CMS proposals but also asks the Agency to provide an exception so that existing RTTs would have an opportunity to expand current RTT programs under limited circumstances.
    • Resetting Low PRA and FTE Counts for Certain Hospitals:  CMS has proposed to allow certain hospitals to reset low or zero PRAs and low FTE caps when hospitals train a requisite number of residents on or after Dec. 27, 2020 (the date of the enactment of the CAA). As proposed, Category A hospitals trained less than 1.0 FTE on any cost report prior to Oct. 1, 1997, and Category B hospitals trained 3.0 FTEs or less between Oct. 1, 1997, and Dec. 27, 2020; each would have a five-year window (ending Dec. 26, 2025) to “trigger” a reset. Category A hospitals would trigger a reset by showing 1.0 FTE or more on a cost report on or after Dec. 27, 2020, and Category B hospitals would do so when they train more than 3.0 FTEs on any cost report after Dec. 27, 2020. The AAMC supports the CMS proposal to allow certain hospitals to reset low or zero PRAs and FTE caps.