CHA has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the federal fiscal year (FFY) 2022 inpatient prospective payment system (IPPS) supplemental final rule for the implementation of graduate medical education provisions of the Consolidated Appropriations Act of 2021 (CAA), including the distribution of additional residency slots.
In the letter, CHA strongly opposed the use of Health Professional Shortage Area (HPSA) scores as the mechanism to prioritize hospitals for distributing residency slots by awarding them to applicants representing HPSAs with higher scores.
CHA encouraged CMS to use the alternative distribution methodology for available residency slots discussed in the FFY 2022 IPPS proposed rule, which prioritizes applicants for the additional slots created by Section 126 of the CAA based on the number of categories for which the hospital qualifies. If CMS does not adopt the alternative distribution methodology, CHA asked that CMS publish the results of the FFY 2023 distribution and seek public comment on them to reassess the methodology finalized in this rule.
Additionally, CHA asked CMS to withdraw the HPSA training time requirement that a hospital that receives one or more slots under Category 4 must attest that at least 50% of the resident’s training time over the duration of the program will occur in an HPSA location, as it may hinder a physician’s ability to gain experience practicing in multiple settings during their residency.