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New Deadline of November 18, 2022 to Challenge Direct Graduate Medical Education HCRIS Data under Section 131 of the Consolidated Appropriations Act of 2021


Under Section 131 of the Consolidated Appropriations Act of 2021, Congress gave certain hospitals with very low FTE resident caps or DGME per resident amounts (“PRA”) an opportunity to reset those low FTE caps and PRAs.  As part of CMS’s implementation of Sec. 131, CMS posted DGME HCRIS data files on its website and allowed hospitals with reopenable cost reports an opportunity to challenge the data, if the hospital had a supportable and documentable basis to disagree with the posted data.

Now, for cost reports that are not reopenable, CMS has opened a Phase 2 which allows hospitals to request changes to the posted DGME HCRIS data.  The requests must be submitted to their Medicare Administrative Contractors no later than November 18, 2022 and the requests must contain complete documentation in support of the hospital’s assertion that the HCRIS data are incorrect and must state the fiscal year begin and end dates and the Notice of Program Reimbursement (“NPR”) date of the cost report(s) the hospital believes are incorrect.

For more information, visit CMS’s link here, or if you have questions, please reach out to David J. Vernon in Washington, D.C., or any other member of the Hooper, Lundy & Bookman team.


David J. Vernon
Washington, D.C.