Richard MacIntosh-CA

Two comments on file code CMS-1430-IFC (Federal Register dated 3/14/11): 1. When a Medicare GME affiliated group includes a hospital that reports and receives only GME reimbursement (e.g. a children's or cancer hospital), please clarify what impact this will have on the redistribution of "unused" IME cap slots. Since the residents would likely qualify for IME reimbursement at an IPPS hospital, it would seem inappropriate to reduce the aggregate IME cap of the affiliated group simply because IME slots were being used by a non-IME hospital. Note that HRSA advised CHGME hospitals receiving cap slots under a Medicare GME Affiliation Agreement with an IPPS hospital to share only the GME cap and not the IME cap. 2. For a hospital that was a member of a Medicare GME affiliated group during their reference cost reporting period, please confirm the "actual cap reduction" cannot exceed their "1996" FTE cap. As an example, a hospital with a "1996" FTE cap of zero would never have an FTE cap reduction. We assume no hospital will be assigned a negative "Final FTE Cap" effective July 1, 2011. Thank you!