ALERT
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October 20, 2004 Conference Call
Information and Registration
The October 4, 2004 Federal Register (69 FR 59259) announces
a Children's Hospitals Graduate Medical Education Payment Program
(CHGME PP) conference call which will be held on Wednesday,
October 20, 2004 from 1:30 PM to 3:30 PM (EST). The agenda for
the conference call will include, but not be limited to: (1)
welcome and opening comments; (2) news releases/updates; (3)
reminders; and (4) "on the horizon" topics of interest.
Time will also be available for a question and answer period.
Agenda items are determined as priorities dictate.
All interested parties who wish to participate in this conference
call must register in advance. Conference call registration
can be accomplished by completing the attached registration
form and faxing it to (301) 443-1879. Registration forms must
be received by close of business, Friday, October 15, 2004.
An agenda and additional conference call information will be
emailed to the primary contact identified for registered participants
one (1) day prior to the scheduled conference call. Registrants
will be notified of a cancellation.
If you have additional questions or we may be of further assistance,
please contact your regional manager.
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TIMELINE FOR RECONCILIATION PAYMENTS
This notice finalizes the closing date for incorporating hearing
determinations by the Provider Reimbursement Review Board (PRRB)
for Federal fiscal year (FFY) payment purposes in the Children’s
Hospitals Graduate Medical Education Payment Program (CHGME
PP). Specifically, for FFY 2004 the final date will be July
15. June 30 will be the final date for subsequent years. If
the PRRB has not reached a decision by such date, determining
the actual number of full-time equivalent residents in a particular
case, the departmentally overseen decision of the CHGME fiscal
intermediary (FI) will stand. A PRRB decision after such date
would be taken into account for payment determinations in the
next FFY.
On June 4, the Department issued a notice seeking comments
on the establishment of a final deadline for PRRB decisions
under the CHGME PP. In response to the proposal, the Department
received six sets of comments from interested parties. Several
respondents recognized the need to establish deadlines for an
annually funded program in which all hospitals are statutorily
tied together though differing on what the exact date should
be. As explained in the initial proposal, July 15 for FFY 2004,
and June 30 for subsequent years was chosen to ensure that the
CHGME PP has time to:
- make payment adjustments to all participating hospitals based
on the reconciliation applications;
- issue recoupment notices for overpayment if needed; and,
- redistribute any recouped funds within the FFY. These requirements
are statutory. The date also allows some time for the Health Resources
and Services Administration (HRSA) Administrator’s review
if necessary.
The Department also received comments underlining the tension
between an annually funded program and the statutory right of
review. While these commenters objected to deadlines of any form,
they failed to outline any mechanism through which the CHGME PP
could complete its statutory –and indeed constitutional—
obligation to disburse all funds prior to the close of the FFY.
Therefore, the Department will adopt the proposed deadlines.
Finally, the Department received comments on the best way to
conduct the auditing process during the FFY and what statutory
changes would be needed to minimize disruption both before the
PRRB and to operate the CHGME PP more efficiently. The CHGME PP
has no authority to change statutory provisions. Secondly, the
CHGME PP’s established, yet evolving, auditing process is
designed to conciliate all interested parties, including participating
hospitals, CHGME FIs, the Department and the PRRB. The statutorily
compressed time for application, audit, dispute resolution and
reconciliation requires some adaptation on the part of all participants.
As stated in the proposal, the PRRB has done a remarkable job
of expediting hearings for this unique program. However, the reasoned
decision making required both at the PRRB and at the HRSA Administrator
level will suffer if forced through a hurried process. Although
the July 15 and June 30 in future years-deadline may present a
challenge for resolving any remaining disputes before the PRRB,
the Department must fulfill its statutory mandate and duty to
all participating hospitals. Continuing PRRB cases may not necessarily
be mooted. A Board decision after such date would be taken into
account for payment decisions in the next FFY.
For further information contact Ayah E. Johnson Ph.D., Chief,
Graduate Medical Branch, Division of Medicine and Dentistry, Bureau
of Health Professions, HRSA, Room 9A-05, Parklawn Building, 5600
Fishers Lane, Rockville Maryland 20857; or by e-mail to ChildrensHospitalGME@hrsa.gov;
or by phone at (301) 443-1058 or (301) 443-6190.
About
the Children's Hospital GME Payment Program
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The
CHGME Payment Program provides funds to freestanding children’s
hospitals to support the training of pediatric and other residents
in graduate medical education (GME) programs. This program
compensates for the disparity in the level of Federal funding for
teaching hospitals for pediatrics versus other types of hospitals.
To
be eligible for funding, by statute (Public Law 106-310), a
children’s hospital must meet all of the following criteria:
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Participates
in an approved graduate medical education (GME) program
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Has a
Medicare Provider Agreement
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Is excluded
from the Medicare inpatient prospective payment system (PPS)
under section 1886(d)(1)(B)(iii) of the Social Security Act,
and its accompanying regulations
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Is a
“freestanding” hospital
A hospital
remains eligible for payments as long as it trains residents
as a “freestanding” children’s hospital during the fiscal year for
which CHGME Payment Program payments are made.
Hospitals
Potentially Eligible to Participate in the CHGME Payment Program
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