On April 24, 2018, the Centers for Medicare & Medicaid Services (CMS) released the agency's fiscal year 2019 inpatient prospective payment system (IPPS) proposed rule. Although the rule contains many proposals relating to hospital payment policy, three GME-related issues are worthy of note to the teaching hospital community.

First, CMS proposes a change relating to new urban teaching hospitals' participation in Medicare GME affiliated group agreements. Under current CMS policy, a new urban teaching hospital that builds DGME and IME caps under the regulations at 42 CFR sections 405.105(f)(1)(vii) and 413.79(f)(1) is only permitted to enter into a Medicare GME affiliated group agreement to receive slots, not to loan its own slots to other hospitals. Under CMS's proposal, new urban teaching hospitals would now be permitted to loan slots to other new urban teaching hospitals beginning July 1, 2019. CMS would continue to prohibit these hospitals from loaning their cap slots to other "existing teaching hospitals," which CMS defines as hospitals whose GME caps were set in the 1996 base year.

Second, CMS proposes to make several modifications to the regulations relating to submission of data through the Intern and Resident Information System (IRIS).  Effective for cost reports filed on or after October 1, 2018, CMS proposes to implement a rule under which a cost report will be rejected for lack of supporting documentation if the IRIS data do not contain the same total counts of DGME and IME FTE residents that are reported on the Medicare hospital cost report.  CMS also proposes to remove the word "diskette" from the regulations and instead to reference "Intern and Resident Information System data."  Comments on these proposals (and all other proposals contained in the FY 2019 IPPS proposed rule) must be received by CMS no later than June 25, 2018.

Third, CMS announced in the proposed rule the next two rounds of GME slot redistribution through the Affordable Care Act section 5506 closed hospital slot redistribution program. Under Round 11, CMS will redistribute 22.36 IME slots and 22.48 DGME slots from closed hospital Affinity Medical Center in Massillon, OH. Under Round 12, CMS will redistribute 12.52 IME slots and 13.53 DGME slots from closed hospital Baylor Scott & White Medical Center - Garland (TX). The deadline for hospitals to apply for these slots is July 23, 2018.

Dentons' Health Care team can help you assess the implications of the proposed rule and can assist with the preparation of comment letters and Section 5506 applications on behalf of your institution.