CMS should reinstate a moratorium on enforcing complex rules that govern whether a teaching hospital can use volunteer preceptors in residency training programs. That was the advice AAFP Board Chair Michael Fleming, M.D., of Shreveport, La., recently gave CMS Administrator Mark McClellan, M.D., PhD.
In an April 28 letter, Fleming said CMS' recent guidance document had failed to clarify the agency's rules governing hospital use of volunteer, community-based preceptors. In fact, the guidance could prove detrimental, he said.
"Since the guidance could very well result in fewer family practices willing to serve as nonhospital sites for the training of residents, the Academy finds the guidance less than helpful and, in some cases, potentially harmful," said Fleming in the letter.
CMS rules require teaching hospitals to use graduate medical education funds to pay "all or substantially all" of the costs -- including community-based supervisors -- for teaching residents. AAFP argues that, because many preceptors volunteer, the hospitals have little to no cost associated with community-based teaching activities.
CMS officials disagree. In a frequently asked questions document (PDF file: 5 pages / 25 KB. More about PDFs.) posted by CMS on April 8, they contended that salaried physicians inherently cannot volunteer and, therefore, teaching hospitals must either pay the preceptors or reimburse CMS for GME funds that should have gone to the preceptors.
The complexity and administrative burden of the requirements as set forth in the document have the potential to impede family medicine training at nonhospital ambulatory sites -- which is inconsistent with Congressional intent," said Fleming in the letter.
At issue are CMS' incorrect assumptions about the nature of physician income in community-based practices:
AAFP: Allow Use of Volunteer Preceptors While Educators, Regulators Clarify Rules
By News Staff
5/9/2005
- Solo-practice physicians derive all their income from patient care, while group-practice physicians on salary are paid regardless of whether or not they see patients.
- Physician salaries are predetermined and are not necessarily based on revenues generated from their patient care activities.
- Once a salaried physician in a group practice volunteers to supervise a resident, some portion of that physician's remuneration must have been intended for resident supervision. This amount must be reimbursed to the practice by the teaching hospital.
"The result is the creation of a paradigm that seems to make it impossible for any salaried physician in a group practice to be recognized as a volunteer because CMS insists that a cost must be attached to resident supervision activity," Fleming said.
By reinstating a moratorium on enforcing the rules, a recommendation made by HHS' Office of Inspector General, CMS would enable community-based residency training to continue uninterrupted while the medical community, educators and CMS officials could develop "reasonable, workable solutions that will support volunteer faculty in resident training," he concluded.
By reinstating a moratorium on enforcing the rules, a recommendation made by HHS' Office of Inspector General, CMS would enable community-based residency training to continue uninterrupted while the medical community, educators and CMS officials could develop "reasonable, workable solutions that will support volunteer faculty in resident training," he concluded.
