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FY 2024 IPPS GME Update

Updated: May 1, 2023

The FY 2024 Proposed IPPS Rulings, brought forth several adjustments that would beneficially impact the Graduate Medical Education (GME) industry.


The full text of the 2024 IPPS Proposed Ruling can be found here: https://public-inspection.federalregister.gov/2023-07389.pdf


Germane Solutions has summarized the 2024 IPPS Proposed Rulings regarding topics that will ultimately affect Graduate Medical Education – for more information, please visit each topic’s blog.


Germane Summary:

o Following the Notice of Closure of St. Vincent Charity Medical Center (CCN 360037), located in Cleveland, OH – the 20th round of Section 5506 is taking place. This round will redistribute 56.73 IME FTEs and 64.66 DGME FTEs. All applications must be submitted by July 10, 2023.


o Rural Emergency Hospitals (REHs) will now be given the same option to be considered a “non-provider” site, which will provide the same financial opportunities previously afforded to Critical Access Hospitals (CAHs). That is, time spent training at REH’s can be claimed as IME and DGME FTEs at the main-training hospital.


o In the FY 2007 IPPS/LTCH PPS final rule, CMS established a rule that hospitals reclassified as rural under § 412.103 are also considered rural under the capital IPPS for purposes of determining eligibility for capital DSH payments. This prevented those hospitals from receiving capital DSH payments. However, CMS is now proposing that effective for discharges occurring on or after October 1, 2023, hospitals reclassified as rural under § 412.103 will no longer be subject to the loss of capital DSH payments.


o In this FY 2024 Proposed Ruling, CMS is revising the policy to which the rural floor is the same as the rural wage index. Hospitals reclassified under §412.103 will no longer be affected by the previous policies, as they will now be included in the calculation of the rural floor. This proposal benefits geographically rural hospitals as the rurally designated hospitals will now be included in the rural floor calculation.


o The Medicare Cost Report (MCR) E Part A – Line 20 instructions will be revised to more clearly indicate how the calculations are performed for the Prior Year Resident-to-bed Ratio. This ratio may be adjusted to properly reflect an increase in the current cost reporting period's resident-to-bed ratio due to residents in a new GME program or new Rural Track Program, a MGMEAA, or due to residents displaced by the closure of a hospital or residency program.


o The percent reduction to MA DGME Payments will be 3.27% for FY 2024. This relatively low reduction factor will produce higher DGME payments for the GME industry.

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