Corporate Compliance

Note from Hugh

Medicare Weekly Update, May 8, 2007

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Acute care hospitals may, at first blush, be inclined to ignore the long-term care hospital final rule published (as a display copy) last week. For teaching hospitals, that could be a mistake. CMS included in the final rule a potentially significant change relating to graduate medical education payments for resident training provided in a non-hospital setting (e.g., community practice setting). In order for teaching hospitals to be able to count resident time spent in a non-hospital setting, the teaching hospital must incur "all or substantially all" of the costs of the non-hospital training program. The final rule revises the definition of "all or substantially all." In general, this change should make it easier for teaching hospitals to meet the "all or substantially all" requirement. Teaching hospitals that sponsor resident training in non-hospital settings may want to re-review their financial relationships with non-hospital resident training sites in light of this change.



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