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  • Washington Highlights

    Medicare GME Overlap Audits


    Brad Cunningham, Sr. Regulatory Analyst, Graduate Medical Education
    For Media Inquiries

    In response to a 2018 Office of Inspector General report that found graduate medical education (GME) full-time equivalent (FTE) overlaps on certain cost reports, the Centers for Medicare & Medicaid Services (CMS) contracted with the accounting firm Myers and Stauffer to work with Medicare Administrative Contractors (MACs) to review submitted cost reports for these overlaps. FTE overlaps occur, generally, when two institutions count a resident on a cost report, and the total amount of time captured for the resident amounts to more than 1.0 FTE. There are many reasons that overlaps may occur, but for Medicare reimbursement, no resident may be counted as more than 1.0 FTE. Myers and Stauffer began notifying institutions of resident overlaps earlier in the summer and will perform yearly audits through fiscal year 2027. Institutions that are notified of overlaps will need to provide supporting documentation, such as rotation or assignment schedules, personnel documentation like resident evaluations, or official documents signed by the resident during their time at the facility. The CMS provides further information on the Interns and Residents Information System website and through this informational handout.