Medicare Pass-Through Funds for Residency Programs
The information contained in this document is not intended to serve as advice or guidance for an individual center. Rather it is designed as an overview of some of the questions related to Medicare Pass-Through funding and the experiences that our centers and staff have had in this area.
By Marc Medwed, Associate Executive Director | July 23, 2018
As many of you are aware, the world of reimbursement for Medicare is one that is complex and often inconsistent. There are many institutions, both within ACPE and outside of ACPE, that are undergoing audits for previous years. Many of these audits are being conducted by non-allied health professionals, so their understanding of how our programs operate and function on a daily basis is limited, which sometimes leads to confusion and additional work to demonstrate a center’s compliance with the regulations.
As a reminder, pass-through funds are only potentially available for programs that qualify a person to be employed in a specialty in which that person could not be employed without this particular educational program. Since it is the industry norm for hospitals to employ only board certified chaplains (a process that requires 1,600 hours of CPE), then a residency of 1,600 hours (4 units) that is designed to enable persons to achieve board certification is eligible for reimbursement, provided that it meets the conditions outlined below.
Even though this is a federally funded program, its implementation and oversight is done on a regional basis. In talking with many of centers and with others who are facing similar challenges, what has become clear is that there is a wide variation in interpretation of what is allowable and what is not, and even within a specific region, these interpretations are inconsistently applied to programs.
However, there are particular items that it is safe to say are “must haves” for a center to be eligible to receive pass-through funds for their residency programs. The following basic information is from the Federal Register, and is a good starting point. Click here
to view the Federal Register documents: 42 CFR 413.85 – Cost of Approved Nursing and Allied Health Education Activities. This section includes the five basic requirements for a hospital to be considered the operator of an approved program, the hospital MUST