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Direct Graduate Medical Education (GME) – Part 1

The purpose of this post is to discuss direct graduate medical education (GME). I will provide an overview of what is required on E-3, Part IV on 2552-96 or the new E-4 on the 2552-10.

What is Direct Graduate Medical Education?

GME compensates hospitals for the costs of running a teaching program. “CMS states:

Medicare direct GME payments are calculated by multiplying the PRA times the weighted number of full-time equivalent (FTE) residents working in all areas of the hospital (and non-hospital sites, when applicable), and the hospital's Medicare share of total inpatient days.
What counts as an approved medical resident program

Please consult 42 CFR 413.75 for the requirements, but that section says that an approved program must meet one of the following requirements:

1. It must be approved by a national organization.
2. It must count toward certification of the participant in a specialty/subspecialty in the stated publications.
3. It must be approved by the Accreditation Council for Graduate Medical Education (ACGME) as a fellowship program in geriatric medicine.
4. It is a program that would be accredited but for requiring induced abortions.

Where is the calculation performed?

Below is E-3, Part IV from 2552-96. The setup is basically the same for 2552-10.

E-3, Part IV - GME Calculation

E-3, Part IV – GME Calculation

1. We start off with line 3.01, which asks for the total number of unweighted resident FTE count for the cost period on/before December 31, 1996. The statistic here shows 125.

2. Line 3.02 says that we can add on to the cap. The section referenced for purposes of 2552-10 is 42 CFR 413.79(e), which applies to hospitals that have established a new teaching program after January 1, 1995.

3. Line 3.03 allows for a boost to the cap when there is an affiliation agreement.

4. Line 3.04 sums up the previous rows. However, it also references a separate worksheet, E-3, Part VI, which calculated the reduction in GME payments due to section 422 of the MMA. Mores specifically, the section provides:

If a hospital's reference resident level is less than its otherwise applicable FTE resident cap as determined under paragraph (c)(2) of this section or paragraph (e) of this section in the reference cost reporting period (as described under paragraph (c)(3)(ii) of this section), for portions of cost reporting periods beginning on or after July 1, 2005, the hospital's otherwise applicable FTE resident cap is reduced by 75 percent of the difference between the otherwise applicable FTE resident cap and the reference resident level. – 42 CFR 413.77(c)http://law.justia.com/cfr/title42/42-2.0.1.2.13.6.51.5.html

This section has since been moved to line 3 of 2552-10. Another line, 3.01, has since been added, which further adjusts the cap:

If a hospital's reference resident level, as defined under paragraph (c)(1)(ii)(B) of this section is less than its otherwise applicable FTE resident cap as determined under paragraph (c)(2) of this section or paragraph (e) of this section in the reference cost reporting period (as described under paragraph (m)(6) of this section), for portions of cost reporting periods beginning on or after July 1, 2011, the hospital's otherwise applicable FTE resident cap is reduced by 65 percent of the difference between the otherwise applicable FTE resident cap and the reference resident level. The reduction shall take into account the hospital's FTE resident cap as reduced under paragraph (c)(3) of this section. – 42 CFR 413.77(m)http://www.law.cornell.edu/cfr/text/42/413.79

We will get to the rest of the calculation in the following sections.

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