Payment Matters: Reminder: CMS Now Permits Electronic Submission of Medicare Graduate Medical Education (GME) Affiliation Agreements

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As all teaching hospitals are aware, Medicare permits hospitals to share Medicare resident FTE cap slots through the use of Medicare Graduate Medical Education (GME) affiliation agreements. Historically, CMS has required that each hospital in the Medicare GME affiliated group submit the Medicare GME affiliation agreement to each hospital’s Medicare contractor, with a copy to the CMS central office, no later than July 1 of the residency year during which the agreement is to be in effect. See 42 C.F.R. § 413.79(f)(1). Too often, this has led to a scramble as hospitals have attempted to negotiate the final terms of an FTE sharing arrangement, memorialize those terms in a Medicare GME affiliation agreement, and mail those agreements by the July 1 deadline. Recently, however, CMS has provided some modest relief from this scramble.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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