FFY 2024 IPPS Final Rule: Graduate Medical Education (GME) and Nursing/Allied Health
Medicare Advantage (MA) Nursing and Allied Health (NAH) Payments for CYs 2010 to 2019
CMS revises the Medicare Advantage (MA) Allied Health funding for certain cost reports in calendar years 2010 through 2019. This change is per Section 4143 of the Consolidated Appropriations Act, 2023 (CAA, 2023) and does not result in any offset to GME funding (i.e., there are no changes to the DGME MA percent reduction amounts2). Prior to the CAA, 2023 the MA NAH pool was limited to $60 million for each respective calendar year and reverts to $60 million beginning with calendar year 2020.
Table 5: Change to Medicare Advantage Nursing and Allied Health Funding
CMS is limiting the MA Allied Health funding changes to cost reports between CY 2010 to 2019 if the respective cost reports are within the three-year reopening period. CMS’s rationale is that each hospital was subject to reductions under CR 11642 (or CR 12596 or CR 2407 as applicable) whereby the MA NAH factors were previously revised within the past three years (between December 2020 and March 2022). Therefore, cost reporting periods affected by the reduction under CR 11642 are within the restarted three-year reopening period and will be revised to reflect the increase in the NAH payment pool. Cost reporting periods not previously reopened for the reduction under CR 11642 (or CR 12596 or CR 2407 as applicable) will not be eligible for reopening to receive the MA Allied Health increase under Section 4143 of the CAA, 2023.
Furthermore, to be eligible for reopening, a hospital must have been receiving interim NAH pass-through payments as of December 29, 2022. Hospitals are also eligible for reopening if the pass-through amount is too small to qualify for interim payments, but the hospital otherwise qualifies for Allied Health reimbursement. CMS states hospitals are ineligible for MA Allied Health funding changes when not reporting NAH costs due to prior audits and/or are under appeal. CMS further notes a successful appeal would restore the revised MA Allied Health payments under Section 4143.
Medicare Advantage (MA) Nursing and Allied Health (NAH) Payments for CY 2022
CMS finalized the Nursing and Allied Health MA add-on rates and direct GME MA percent reductions for CY 2022 (see Table 6 below). The figures were based on cost reports ending in FY 2020 from the fourth quarter 2022 HCRIS update. For CY 2023, CMS will publish those rates in the IPPS proposed rule for FY 2025.
Table 6: GME Medicare Advantage Reduction for FY 2022
Medicare GME Affiliation Agreements | Rural Track Medicare GME Affiliation Agreements
CMS issues clarifying guidance on determining prior year IME resident FTE counts when a provider is participating in a Medicare GME affiliation agreement or rural track Medicare GME affiliation agreement, and the provider increased its current year FTE cap. CMS clarifies that providers add the lower of the following to the prior year cost report’s “current year allowable FTEs” (E Part A Line 12):
Difference between the current year three-year average FTE count (E part A Line 15) and the prior year allowable FTE count (prior year cost report E Part A Line 12), and
The FTE cap increase per the affiliation agreement (difference of current and prior year cost report “adjustment (increase or decrease) to the FTE count” on E part A Line 8)
GME Training at New Rural Emergency Hospitals (REHs)
CMS finalized that effective for cost reporting periods beginning on or after October 1, 2023, REHs may be considered a non-provider site. Thus, other hospitals may include in their direct GME and IME FTE counts residents training in approved programs at REHs if the REH is not incurring the cost of the residents. If the REHs elect to incur the cost of the FTE residents, the REHs are no longer considered a non-provider site and Medicare payment to the REHs can be made at 100% of the reasonable cost.
For more information, please contact Tom Hubner at tom.hubner@toyonassociates.com or Scott Besler at scott.besler@toyonassociates.com.
2 As specified in Change Request (CR) 11642 for CYs 2010 through 2017, CR 11642 for CY 2018, and CR 12407 for CY 2019.