CMS reviewing for duplicate intern and resident full-time equivalents

The Centers for Medicare and Medicaid Services (CMS) announced a Duplicate Interns and Residents Full-Time Equivalents (FTEs) Review project on May 3, 2023.

The primary goal is to identify and resolve duplicate FTEs, which will require Medicare Part A teaching providers to supply documentation to support their claimed FTEs. Myers and Stauffer LC, a CMS contractor, has been contracted to complete reviews of all Intern and Resident Information System (IRIS) duplicates and has begun reaching out to providers.

IRIS

Teaching hospitals are required to submit IRIS files as part of the Medicare cost report submission. These files list interns and residents — and their assignment periods — also known as rotations. Assignment periods determine FTE counts claimed in the cost report, forming the basis for DGME and IME reimbursement.

CMS maintains an internal master IRIS system that validates IRIS files sent by all providers nationwide and identifies overlaps where multiple hospitals claim reimbursement for the same resident.

IRIS file format changes

CMS announced changes to the IRIS file submission files, Inpatient PPS Rule, in federal fiscal year (FFY) 2021. The new file format, IRIS XML format, is required for providers claiming IME and GME FTEs for cost reporting periods beginning on or after Oct. 1, 2021. Prior submissions consisted of two dBase database files, master and assignment.

Background

Hospitals that train residents incur significant costs beyond those associated with providing patient care. The Medicare program makes payments to teaching hospitals for a portion of these added costs through two mechanisms.

The Direct Graduate Medical Education (DGME) payment compensates teaching hospitals for a portion of the costs directly related to training residents. DGME is paid on a per resident amount (PRA) as a separate pass-through payment, separate from the Medicare Severity Diagnosis Related Groups (Mississippi-DRG) payment.

The Indirect Medical Education (IME) payment compensates teaching hospitals for indirect costs involved in training residents. The hospital’s IME payment is determined with a Medicare formula that adds the hospital’s intern-to-bed ratio (IRB) into the calculation.