When Congress placed limits or "caps" on the number of full-time equivalents
(FTEs) that a hospital could count for direct graduate medical education
(DGME) and indirect medical education (IME) purposes, it expressly required
the Secretary to prescribe rules addressing medical residency training
programs established on or after January 1, 1995. CMS, consistent with this
directive, provided for an exception to the FTE caps if the hospital had no
allopathic or osteopathic residents in its most recent cost reporting period
ending on or before December 31, 1996, and it established such a program on
or after January 1, 1995. Thomas W. Coons of Ober|Kaler discusses.
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