OIG Request For Info On Resident Rotations To Nonprovider Settings

The OIG is sending letters to a large number of teaching hospitals requesting information on whether the hospital had written agreements in place for rotations to nonprovider settings for academic year 2004, purportedly pursuant to a requirement in the Medicare Prescription Drug, Improvement and Modernization Act ("MMA"). Hospitals probably have a duty to respond under a regulatory requirement for such written agreements; and any response must be accurate. There may be instances, however, where a written agreement can be construed to exist from other documents or where no agreement should be required because the nonprovider site is a part of the same legal entity as the hospital. The OIG request is directed to hospitals' GME offices for a response within 15 days. In order to avoid the submission of incomplete or incorrect information that may cause a hospital problems unnecessarily, the GME office should consult with finance and reimbursement personnel and legal counsel prior to