to ensure that total national general, non-Medicare payment remains within the general, non-Medicare IME fund limit for the year.

  • An institution's Medicare capitated patients' percentage of that institution's total Medicare caseload should be calculated and used as a coefficient to appropriately modify the IME formula PPS adjustment in the formula half of Medicare IME payment to account for capitated patients in the distribution of formula IME support.

  • Current IME payment should be restricted exclusively to teaching hospitals. Study of the design and the effects of a wider distribution to cover indirect teaching costs in other settings that are accredited and recognized for payment by the National GME Trust Fund should be undertaken.

  • The amount of time residents spend in approved, affiliated ambulatory training sites as part of an institution's Accreditation Council for Graduate Medical Education/American Osteopathic Association (ACGME/AOA) approved residency program should be counted for hospital IME payment purposes just as it is for DME payment.*


 The committee's use of the term "non-Medicare" share or caseload always excludes the Medicaid share or caseload. Medicaid pays for GME separately in almost every state. A GME trust fund would double pay if applied to a Medicaid share or caseload.

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