Skip to Content

Filter by:

Washington Highlights

AAMC Shares Concerns With CMS About Protecting Graduate Medical Education and Network Adequacy on the Exchanges

March 22, 2013—AAMC Mar. 15 submitted comments  to the Centers for Medicare and Medicaid Services (CMS) in response to a draft Letter to Issuers on the Federally-facilitated and State Partnership Exchanges that are being established under the Affordable Care Act (ACA, P.L. 111-148 and P.L. 111-152).  The Association’s comments focused on the need for CMS to set and enforce network adequacy and essential community provider (ECP) standards for the exchanges that will protect graduate medical education and access to teaching hospitals because of the unique and critical role these institutions serve in their communities.  AAMC highlighted the fact that teaching hospitals are often the sole providers of specialized tertiary care, including 97 percent of bone marrow transplants, 98 percent of kidney transplants, 80 percent of level 1 trauma and burn beds.

AAMC strongly urged CMS to ensure that the guidance does not allow cost to become the primary driver of network design.  This could prevent exchange enrollees from accessing teaching hospitals because of the legitimately higher expenses associated with graduate medical education, and making advanced technologies and clinical expertise available to all comers, including the sickest, most complex, and most vulnerable patients.

AAMC explained that CMS’ guidance should include standards to prevent QHP issuers from creating tiered networks or solely prioritizing lower premiums without considering the impact on the quality of the providers in the network or compensation for graduation medical education.  If CMS does not establish these standards early on, the reform of the insurance marketplace could have the unintended consequence of denying millions of individuals access to the specialized lifesaving services that teaching hospitals provide and, at the same time, jeopardize the funding necessary to train enough doctors to care for a growing insured population.


Christiane Mitchell
Senior Director Health Care Affairs
Telephone: 202-828-0461

Allison M. Cohen, J.D., LL.M.
Senior Policy and Regulatory Specialist
Telephone: 202-862-6085


envelope on a green background

Subscribe to Washington Highlights

RSS icon

Subscribe to RSS

Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

Past Issues

For More Information

Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806