Proposed Modifications to Criteria for New Residency Programs

Hey GME Community,

I stumbled upon an intriguing article from Germane Solutions on LinkedIn titled "Potential GME Impact Following CMS 2025 IPPS Proposed Rules." After reading it and delving into the Centers for Medicare & Medicaid Services (CMS) published 2025 IPPS Proposed Rules, starting on page 670, I contemplated the potential implications for the GME community.

Background:

CMS is mulling over adjustments to the criteria for applying the Direct Graduate Medical Education (DGME) cap for medical residency training programs established after January 1, 1995. These tweaks also extend to the Indirect Medical Education (IME) adjustment. The rules governing these criteria have been in place since the late 1990s with subsequent updates.

Proposed Changes:

CMS is opening the floor for comments and seeking to redefine what constitutes a "new" residency program. They're particularly interested in input on eligibility for additional Medicare-funded GME slots. Here's a glimpse into what they're pondering:

• Newness of Residents pg.671:?CMS proposes that for a residency program to be considered new, at least 90 percent of individual resident trainees must not have previous training in the same specialty. They aim to establish a clear standard for determining the "overwhelming majority" of new residents. CMS suggests that at least 90 percent of individual resident trainees must lack previous training in the same specialty for a program to be considered new.
• Newness of Faculty and Program Director, pg.674:?The need for experienced teaching staff in new programs is recognized. However, CMS seeks input on what proportion of faculty should have no previous experience teaching in the same specialty. They suggest a threshold of up to 50 percent of teaching staff from previously existing programs in the same specialty. While recognizing the need for experienced teaching staff, CMS seeks feedback on what proportion of faculty should have no prior teaching experience in the same specialty.
• Commingling of Residents:?What does commingling mean??Commingling refers broadly to the mixing of funds belonging to one party with funds belonging to another party. It most often describes a fiduciary's improper mixing of their personal funds with funds belonging to a client. CMS is exploring the appropriateness of residents from separately accredited programs in the same specialty, sharing training experiences. They are seeking input on the extent to which commingling should be allowed and how it may impact program classification and funding.
• One Hospital Sponsoring Multiple Programs:?CMS is seeking comments on the permissibility and reasons behind hospitals sponsoring multiple programs in the same specialty. They are also interested in understanding the extent of commingling in these programs. This is important for residency programs because it directly impacts the operational landscape and funding allocations. CMS's interest in the permissibility and rationale behind hospitals sponsoring multiple programs in the same specialty signals a potential reevaluation of program diversity and distribution. Residency programs must stay informed and engaged in this process to anticipate potential regulatory changes and adjust their strategies accordingly to ensure program sustainability and compliance.

Impact on Residency Programs and GME Coordinators:

These proposed changes could significantly reshape residency program structures and management approaches. The definition of a "new" program will dictate eligibility for additional Medicare-funded GME slots, potentially influencing funding and expansion plans.

What Can Programs Do?

As CMS progresses with these rules, residency programs and GME coordinators can navigate the changes by staying informed. It's crucial to stay informed about CMS updates regarding the proposed modifications. Amidst our many responsibilities, this is an area that warrants our attention. Participate in the comment solicitation to ensure that the proposed criteria truly reflect the realities of residency programs. Who understands the intricacies of program management better than us? This is our chance to offer valuable insights and advocate for what is necessary. Let's engage in discussions with our program directors, GME offices, or leadership teams to ensure our voices are heard. Take a seat at the table and submit your input to shape the future of graduate medical education. Be prepared to adjust recruitment and hiring practices to align with the proposed criteria for new residents and faculty members. Advocate for considerations unique to small or rural-based programs during the comment period.

These proposed modifications highlight the importance of active engagement from residency programs and GME coordinators in shaping regulations affecting graduate medical education. Your feedback and participation in the comment process are crucial to ensuring that these changes serve the best interests of residency programs nationwide.

Remember, the comment period closes on June 10th at 5 pm EST. Make sure to voice your thoughts!

Read the full article here

Access the comment submission portal

Select from the dropdown list if you're academic, choose - Academic OT005

Stay informed, stay engaged!

Where you can find me and follow:

• Instagram -?@gmeadmin_insights
• TikTok -@gmeadmin_insights
• Apple Podcast?@GME Admin Insights
• Spotify Podcast?@GME Admin Insights
• YouTube?@GMEAdmin_Insights?