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| Children’s
Hospitals Graduate Medical Education Payment Program
CHGME PP ALERT - April 2008 In this alert:
The Children’s Hospitals Graduate Medical Education Payment Program (CHGME PP) has recalculated payments based on changes reported by children’s hospitals in their Federal fiscal year (FY) 2007 reconciliation applications. Revised notice of award letters are in the process of being sent to children’s hospitals identifying adjusted payment amounts. Changes to monthly payments to reflect adjustments as a result of the Resident Full-Time Equivalent (FTE) Assessment Program and the processing of participating children’s hospitals reconciliation applications will begin in July 2007. At the end of the FY, the CHGME PP may make a final payment to distribute any remaining funds, including those funds that have been returned to the DHHS during the course of the FY as a result of overpayment or hospitals’ loss of eligibility. If this occurs, hospitals will be notified in writing of the payment.
Beginning on July 1, 2007, the FY 2008 CHGME PP application guidance and forms will be available on the CHGME PP website at http://bhpr.hrsa.gov/childrenshospitalgme/apply.htm. The application cycle consists of an initial application and a reconciliation application (see introduction and guidance on the above website link). Children's hospitals that are not eligible to participate in or do not apply for FY 2008 CHGME PP funding during the initial application process are not eligible to apply for and receive funding during the reconciliation application process for the same FY. It is imperative that all applicant hospitals, including those that have previously participated in and received CHGME PP funding, thoroughly read the detailed application guidance and instructions before completing the required application forms as the instructions and forms have changed in response to recent CHGME PP-specific statutory changes and Centers for Medicare and Medicaid Services (CMS) policies affecting the CHGME PP. The following additional information is provided to assist you in your preparations for the FY 2008 application cycle: Application Filing Requirements: Initial applications must be submitted in English, typed, and include the completed HRSA 99, HRSA 99-1, HRSA 99-2, HRSA 99-3, HRSA 99-5 and any required supporting documentation. Supporting documentation may include, where applicable, but is not limited to: copies of Medicare Graduate Medical Education (GME) Affiliation Agreements in support of changes to an aggregate cap and copies of each Medicare cost report (MCR) CMS-2552-96 (Worksheets E-3, Part IV and E-3, Part VI) used to complete the CHGME PP application. If changes or modifications have been made to supporting documentation (e.g., the Medicare GME Affiliation Agreement was revised to reflect changes in resident rotations, etc.) please ensure that the most recent, up-to-date version is submitted with the hospital’s CHGME PP application. Hospitals are required to submit the original and one copy of the completed, signed application, any required supporting documentation and a diskette containing copies of the hospital's completed CHGME PP HRSA forms. Initial applications must be mailed to the address provided and postmarked by August 1, 2007. Use of an overnight courier is strongly recommended. The reconciliation application process for FY 2008 CHGME PP funding will commence on or about April 1, 2008 and will conclude on May 1, 2008. Reconciliation applications must be postmarked by May 1, 2008. To assist CHGME PP staff in uploading the electronic version of your completed application forms to our database system, we also ask that you:
Confirmation of Receipt of Application (by the CHGME PP): Upon receipt of your application, the application package will undergo an initial review to ensure that all required application forms and supporting documentation, etc. are present. Following this initial review, an application confirmation "receipt" will be emailed to the contact person identified on line 6 of the HRSA 99. The receipt will indicate whether or not your application is complete (i.e., all applications forms are present) and, if applicable, a list of forms or supporting documentation that are incomplete or missing. Please note that if an application is considered incomplete, it will not be processed until all required forms and/or supporting documentation are received. Hospitals will have 48 hours, from the date of the email, to complete and submit an original and one copy of the requested forms and/or documentation, by mail, to the CHGME PP. Materials must be postmarked within 48 hours of the date of the email notice. Again, use of an overnight courier is encouraged. Facsimiles will not be accepted.
§422 of the Medicare Modernization Act of 2003: As you are aware, in December 2003, the President signed the Medicare Modernization Act (MMA) of 2003 (also known as the Medicare Prescription Drug and Improvement Act of 2003), Public Law 108-173. §422 of the MMA, added Section 1886(h)(7) to the Social Security Act (SSA). This provision reduces the 1996 Base Year Cap for certain hospitals and redistributes those positions to other hospitals that applied for and received an increase to their 1996 Base Year Cap under §422. Authority for implementing §422 of the MMA was delegated to the CMS. Under the CHGME PP statute, by incorporation of SSA provisions, the CHGME PP must implement the counting law and rules of Medicare, which include those related to the implementation of §422 of the MMA. In response to this requirement, the CHGME PP has extensively reviewed the impact of §422 of the MMA on its determination of resident FTE counts for CHGME PP purposes and modified the CHGME PP application guidance and forms accordingly. For more in depth information regarding the CHGME PP’s implementation of §422 of the MMA please refer to the FY 2008 CHGME PP Application Guidance and Forms on the CHGME PP website (link provided above). §422 of the MMA and its accompanying rules and regulations also required the CHGME PP to modify its direct and indirect medical education payment formulas to accommodate the aforementioned changes. A CHGME PP (email) alert was issued on February 23, 2006 addressing the payment formula changes. Case Mix Index: Children's hospitals requesting funding for the FY 2008 application cycle, must submit a case mix index (CMI) based on the discharges from the most recently filed MCR for hospitals that file full MCRs or the most recently completed MCR period for hospitals that file low or no-utilization MCRs, using CMS-DRG Version 23 with the appropriate CMS Version 23 weights reported to the ten-thousandth decimal place. As stated in previous CHGME PP alerts, Public Law 108-490 amended program rules regarding the determination of payments for indirect medical expenses associated with operating approved medical residency training programs. The amendment requires the exclusion of (1) healthy newborns from the calculation of the case mix index; and (2) beds and bassinets assigned to healthy newborns from the available bed counts. Public Law 108-490 became effective for payments for periods beginning with FY 2005. Wage Index (Update): Public Law 109-307, which reauthorized the CHGME PP, requires the CHGME PP to update the wage index (WI) annually, as applied under section 1886(d)(3)(E) of the Social Security Act (SSA). In accordance with this statutory requirement, the CHGME PP will use CMS FY 2007 WI rates (published at http://www.cms.hhs.gov/) in calculating payments for the FY 2008 application cycle. Please note that the out-migration adjustments as well as other types of wage index reclassifications do not apply to the CHGME PP. As described at section 1886(d)(3)(E), only the pre-reclassification wage index, adjusted for occupational mix, is applicable for CHGME PP purposes The CHGME PP will notify each participating children’s hospital, in writing, of the FY 2007 county-specific WI rate that will be used to calculate the hospital’s FY 2008 CHGME PP payments. Each participating children’s hospital will be required to sign and return the notification letter (to the CHGME PP) confirming that the information is correct and the WI identified is consistent with the aforementioned CMS publication. If you require additional information, assistance, or do not agree with the published FY 2007 WI for your county, please contact your CHGME PP regional manager no later than August 1, 2007. Academic Year 2007-2008 Medicare GME Affiliation Agreement (for an Aggregate Cap): Hospitals planning to participate in a Medicare GME Affiliation Agreement for Academic Year 2007-2008 (July 1, 2007 – June 30, 2008) are reminded that July 1, 2007 is the filing deadline to submit completed, fully executed, signed Medicare GME Affiliation Agreements to your Medicare fiscal intermediary (FI) with a copy to the CMS. Questions regarding Medicare GME Affiliation Agreements should be directed to your Medicare FI. Documentation to Support Residents Claimed in the FY 2008 Application: Hospitals are strongly encouraged to continue working with their Directors of GME, Program Directors, Department Chairmen, CHGME FI, etc. to ensure that they have the necessary documentation to support the resident FTEs to be claimed in their FY 2008 initial application for CHGME PP payments. As a reminder, the Documentation Guidance document (available at http://bhpr.hrsa.gov/childrenshospitalgme/apply.htm) was designed to complement the Resident FTE Assessment process and is intended to assist participating hospitals in collecting and providing the documentation necessary for the CHGME PP and its FTE resident count assessment process. The checklists included in the Documentation Guidance are not exhaustive in nature, but they represent the minimum documentation that will allow a children’s hospital’s CHGME FI to accurately assess the resident FTEs reported by the children’s hospital in its initial application for CHGME PP funding. Hospitals are encouraged to discuss all documentation questions with their CHGME FIs prior to the next assessment process which will begin in October 2007! Please note that CHGME FIs may request additional information or clarification as needed to facilitate the FTE resident assessment process.
The CHGME PP continues to work with its Contract Office to secure a contractor to carry out the logistical requirements for a CHGME PP technical assistance workshop in 2007. The CHGME PP is hopeful that a contractor will be in place within the next month so that it can begin planning a three-day technical assistance workshop. Although a location and specific dates are not available at this time, the CHGME PP anticipates that the workshop will be on or around October 2007 in the Washington, DC metropolitan area. As soon as a contractor is in place and the location and dates for a workshop have been confirmed, a CHGME PP alert will be sent. If you have questions or topics that you would like addressed during this workshop, please submit your suggestions in writing to your CHGME PP regional manager (see “CHGME PP Contacts” below).
As discussed during our December 2006 conference call, reported in previous CHGME PP alerts, and the Federal Register (70 FR 26640), the CHGME PP was reauthorized for a period of five years in October 2006 by Public Law 109-307. The reauthorizing legislation requires that participating children’s hospitals provide information about their residency training programs in an annual report that will be an addendum to the hospitals’ annual application for CHGME PP funding. Data are required to be collected on the 1) types of training programs that the hospital provided for residents such as general pediatrics, internal medicine/pediatrics, and pediatric subspecialties including both medical subspecialties certified and non-medical subspecialties; 2) the number of training positions for residents, the number of such positions recruited to fill, and the number of positions filled; 3) the types of training that the hospital provided for residents related to the health care needs of difference populations such as children who are underserved for reasons of family income or geographic location, including rural and urban areas; 4) changes in residency training including changes in curricula, training experiences, and types of training programs, and benefits that have resulted from such changes and changes for purposed of t raining residents in the measurement and improvement and the quality and safety of patient care; and 5) the numbers of residents (disaggregated by specialty and subspecialty) who completed training in the academic year and care for children within the borders of the service area of the hospital or within the borders of the State in which the hospital is located. The CHGME PP is currently working with a contractor to develop a reporting instrument for hospitals to use to report the required data. Although the instrument is still in development, significant progress has been made and the CHGME PP is hopeful that the instrument will be ready for hospitals to use by late Fall 2007. As mentioned above, the annual report will be an addendum to each participating children’s hospital’s (initial) application for funding. For planning purposes, the following timeline is anticipated for the release and completion of the annual report by participating children’s hospitals:
Please note that these dates are provided for planning purposes only and are subject to change. The CHGME PP is fully aware of the additional time and effort associated with this new statutory requirement and is working very hard and taking every step necessary to minimize the additional burden placed on participating hospitals in meeting this requirement.
As always, if additional information or assistance is needed, please contact your designated regional manager:
If you are unaware or unsure of which region your facility or organization should contact, please go to http://bhpr.hrsa.gov/childrenshospitalgme/contacts.htm. |
