Graduate Medical Education Payments for Fellows
Hall Render’s Direct Graduate Medical Education (“DGME”) Group Appeal challenges past DGME payments affected by the FY2023 IPPS Final Rule which made corrections in the DGME payment calculation. CMS admitted in the 2023 Rule that its former DGME rule counted FTEs in a manner contrary to the statute, as found in the Hershey case. Instead of implementing the .5 weighting Congress clearly directed for Fellows and Residents post-Initial Residency Period (“IRP”) in order to increase DGME payments, CMS’s calculation had the opposite impact. Though CMS states its payment correction is “applicable to all payments, both past and future,” retroactively to 2001, CMS is only applying it to cost reports still open when the Final Rule was published.
Join Hall Render attorneys Maureen Griffin, Heather Mogden and Liz Elias for a webinar on Wednesday, December 21 at 1:00 pm. We believe the new retroactive rule should be applied to not just open cost reports, but cost reports within the three-year reopening window and all impacted cost reports from 1997 forward. Eligible participants include teaching hospitals with Fellows/Post-IRP Residents and a total unweighted FTE count that exceeds their 1996 GME cap.
Download Slides | Protested Item Computation Toolkit
