Graduate Medical Education Payment Implications of the Healthcare Reform Law Part II: CMS Issues Final Regulations

 | 1:00am EST

On November 2, 2010, Centers for Medicare & Medicaid Services (CMS) released its final rule implementing the changes to the direct and indirect graduate medical education (GME/IME) Medicare payment provisions that Affordable Care Act (ACA) required. CMS interpretations of these ACA provisions will affect their legal, operational, and financial impact on many academic medical centers and other teaching hospitals. While the final rule adopted many of the interpretations contained in CMS July 2, 2010, proposed regulations, CMS has made some important modifications and clarifications.

This webinar is a follow-up to AHLA’s June 8, 2010 webinar, which discussed the statutory GME/IME provisions of ACA and identified some areas where CMS’ interpretations of those provisions would be important. With the final regulations now available, our expert panel will discuss the GME/IME-related changes of ACA and CMS interpretations of those changes.

The topics covered during this session will include:

  • Counting resident time in nonhospital settings, including the costs that the hospital must bear and documentation requirements;
  • Counting resident time for didactic and scholarly activities and other activities, including the impact of pending litigation;
  • Permanent reductions of unused full-time equivalent (FTE) caps, including the impact of Medicare GME affiliation agreements on the calculation of unused FTE caps; and
  • Process and methodologies for redistribution to hospitals of the unused FTE caps.


  • Auburn Daily, Esquire
    Principal Counsel – Health Law
    University of California, Oakland, CA
  • Karen S. Fisher, JD
    Senior Policy Counsel
    Association of American Medical Colleges, Washington, DC
  • Miechal Lefkowitz
    Technical Advisor, Division of Acute Care
    Centers for Medicare & Medicaid Services, Baltimore, MD
  • Kenneth R. Marcus, Esquire (Moderator)
    Honigman Miller Schwartz & Cohn LLP, Detroit, MI
  • Andrew D. Ruskin, Esquire
    Morgan Lewis & Bockius LLP, Washington, DC

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