GME Payments: Resident Time in Nonpatient Care as Part of Approved Residency Programs, June 2006

Published Thursday, June 1, 2006 7:00 am

Mark B. McClellan, M.D., Ph.D.
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1488-P
P. O. Box 8011
Baltimore, MD 21244-1850

Dear Dr. McClellan:

The American Association for Geriatric Psychiatry (AAGP) is pleased to submit these comments on the proposed rule for Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal Year 2007 Rates. The AAGP is a professional membership organization dedicated to promoting the mental health and well-being of older people and improving the care of those with late-life mental disorders. Our membership consists of more than 2,000 geriatric psychiatrists as well as other health care professionals who focus on the mental health problems faced by senior citizens.

AAGP strongly urges CMS to rescind the purported “clarification” in the proposed rule that excludes medical resident time spent in didactic activities in the calculation of Medicare direct graduate medical education (DGME) and indirect medical education (IME) payments.

The proposed rule cites journal clubs, classroom lectures, and seminars as examples of didactic activities that must be excluded when determining the full-time equivalent resident counts for all IME payments (regardless of setting), and for DGME payments when the activities occur in a nonhospital setting, such as a physician’s office or affiliated medical school. The stated rationale for the exclusion of this time is that the time is not “related to patient care”.

This position is in stark contrast to CMS’s position as recently as 1999, at which time the Director of Acute Care clarified that patient care activities should be interpreted broadly to include “scholarly activities, such as educational seminars, classroom lectures . . . and presentation of papers and research results to fellow residents, medical students, and faculty.” We concur with CMS’s 1999 position. These activities are an integral component of the patient care activities engaged in by residents during their residency programs.

With the possible exception of extended time for “bench research,” there is no residency experience that is not related to patient care activities. The learning model used in graduate medical education (GME) is delivery of care to patients under the supervision of a fully trained physician. Everything that a resident physician learns as part of an approved residency training program is built upon the delivery of patient care and the resident physician’s educational development into an autonomous practitioner.

We urge CMS to rescind its clarification in the proposed rule relating to the counting of didactic time for purposes of DGME and IME payments and to recognize the integral nature of these activities to the patient care experiences of residents during their residency programs.

AAGP appreciates your consideration of our views on this proposal.


Christine M. deVries
Executive Director