On August 1, CMS released the FY 2025 IPPS Final Rules. As mentioned in a previous blog, Potential GME Impact Following CMS 2025 IPPS Proposed Rules, there were several areas related to GME as part of the 2025 Proposed Rules that Germane Solutions was actively monitoring for finalization after submitting our comments in response to the RFIs.
The areas being monitored for feedback from CMS included:
Newness of Residents
Newness of Program Director and Faculty
Number of Residents to Constitute a "Small" Program for Rural Sites
One Hospital Sponsoring Two Programs in Same Specialty
Commingling of New and Existing Residents
Unfortunately, while the GME community responded in force to CMS’s proposed rules, there were no decisions to finalize this information. Instead, CMS is soliciting additional input through a Request for Information (RFI) to refine its approach. An official RFI has yet to be opened for comment/information submission. This RFI will seek further comments on the criteria for newness of residents and how to balance the need for new program integrity with practical considerations for small and rural programs. The proposed rules to be published in April 2025 will provide the next impression of the rules CMS is looking to implement.
Although the FY 2025 IPPS Final Rules did not provide substantiative updates regarding program newness specification, recall the other updates from the FY 2025 IPPS proposed rules published in April. 200 GME positions were authorized under section 4122 of the Consolidated Appropriations Act, 2023, and the proposed rules state that all qualifying hospitals will receive up to 1.0 FTEs and the remaining slots will be distributed to hospitals with the highest Health Professional Shortage Area (HPSA) score. Similarly, rounds 4 and 5 of Section 126 will prioritize geographic HPSAs for slot distribution.
Germane Solutions will continue to provide updates as additional guidance is shared on how to provide feedback on the aforementioned areas.
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