Articles and Blogs

On May 10, 2022, CMS published its proposed revisions to the Inpatient Prospective Payment System for 2023. CMS proposed two changes that would affect reimbursement for graduate medical education (“GME”) programs at teaching hospitals. First, CMS proposed to update the way that it calculates direct GME (“DGME”) payments for fellows in some training programs,... READ MORE

Recent regulations from the Centers for Medicare & Medicaid Services (“CMS”) based on the GME changes in the Consolidated Appropriations Act, 2021 (“CAA”) create new funding opportunities for many teaching hospitals. Opportunities are available for hospitals in the following categories: CMS will award 1,000 new FTE cap slots over the next five years. CMS... READ MORE

This client alert is Part 5 of our series providing insight into Medicare graduate medical education (“GME”) reimbursement changes that occurred in 2021. Part 1, which addressed resident moonlighting and redocumentation requirements, is available here. Part 2, which addressed billing requirements for physicians at teaching hospitals (the “PATH” rules) and the rules regarding cap... READ MORE

The Consolidated Appropriations Act (“Appropriations Act”) that Congress passed in late December 2020 contained a number of provisions that will be of benefit to teaching hospitals. This article is Part 3 of our series providing insight into these CMS changes and more recent statutory changes. Part 1, which addresses resident moonlighting and redocumentation requirements,... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) published numerous updates to its rules for graduate medical education in 2020, many of which take effect in the early part of 2021. This client alert is Part 2 of our series providing insight into these CMS changes and more recent statutory changes. Part 1, which... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) published numerous updates to its rules for graduate medical education in 2020, many of which take effect in the early part of 2021. This client alert is part one of our three-part series giving insight into these CMS changes and more recent statutory changes. Moonlighting Rule... READ MORE

CMS finalized a proposal to allow the temporary transfer of Medicare graduate medical education (“GME”) full-time equivalent (“FTE”) cap slots from teaching hospitals that terminate their Medicare provider agreement or close a residency program to hospitals that continue training their departing residents or fellows. CMS made relatively few changes to the rule that it... READ MORE

Mergers and acquisitions in the health care industry present unique challenges that are not often present when undertaking transactions in other industries. Because of health care’s highly regulated nature, parties may falter if a health care transaction is not reviewed and negotiated carefully with respect to all of the components of health care regulation.... READ MORE

On May 29, 2020, CMS published its 2021 IPPS Proposed Rule (“Proposed Rule”). If adopted, the Proposed Rule would change CMS’s funding methods for graduate medical education (“GME”), giving additional flexibility to hospitals that train residents who are affected by a hospital or residency program closure. Comments on the Proposed Rule are due on... READ MORE

Teaching hospitals, teaching physicians and other providers will have additional flexibility to respond to the COVID‑19 public health emergency (“PHE”) under an interim final rule with comment period (“Rule”) that CMS published on May 8, 2020. The Rule should work to stabilize teaching hospitals’ graduate medical education (“GME”) payments during the COVID‑19 PHE, and... READ MORE