CHGME
PP ALERT - April 2008
In
this alert:
FY
2007 Final Payment Determination and Disbursement (Based Upon
the Reconciliation Application Cycle) |
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.
FY
2008 Application Cycle Guidance and Forms |
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:
- do not add any letters or characters after your Medicare provider
number on the application forms;
- do not identify the CMS-DRG version used to calculate your
CMI on the HRSA 99-2 application form [by signing the HRSA 99-3,
your institution is certifying that it has used the appropriate
CMS-DRG version identified (below) in this alert];
- double check to ensure that your Medicare provider number is
identified on each application form in the appropriate line/space;
- double check to ensure that your Medicare provider number is
identified first in the name/title of each application form file
saved and submitted to the CHGME PP on diskette (ex. 01-3399
HRSA99_1_2_4.xls); and
- do not add any commas or other punctuation in the name of the
files when you save your completed application forms to the diskette;
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.
Related
Policies and Regulations (to the FY 2008 CHGME PP Application
Cycle) |
§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.
CHGME
PP Technical Assistance Workshop 2007 |
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).
CHGME
PP New Annual Reporting Requirements |
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:
- On or about October 2007: Annual Report Training
Session. This training should be attended by all individuals,
at the hospital-level, involved in gathering and/or completing
the Annual Report for hospitals. The training will be conducted
during the CHGME PP Technical Assistance Workshop.
- December 1, 2007: CHGME PP Annual Report Package
will be released (to hospitals). The reporting tool will be made
available for hospitals to download from the CHGME PP website
on or about this date.
- January 15, 2008: Deadline for participating
children’s hospitals to submit their completed Annual Report to
the CHGME PP. Hospitals who fail to submit their completed annual
report by this date are subject to penalty.
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.
CHGME
PP Regional Managers (Primary Contacts for Hospitals and Other
Interested Parties) |
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. |