PUBLIC FUNDING FOR PHARMACY RESIDENCY TRAINING

To support legislation and regulation that ensures public funding for accredited pharmacy residency programs consistent with the needs of the public and the profession; further,

To oppose legislation or regulation involving reimbursement levels for graduate medical education that adversely affects pharmacy residencies at a rate disproportionate to other residency programs.

Rationale

Many organizations capitalize on pass-through funding to maintain the operation of postgraduate year 1 (PGY1) pharmacy practice residencies. Another source of reimbursement for eligible PGY1 pharmacy residency programs is Medicare+Choice Nursing and Allied Health Education Program Payments. In recent years, Centers for Medicare & Medicaid Services (CMS) audits of pharmacy residency programs have resulted in significant cost disallowances, some over a number of years and in amounts that threaten program viability. Many of these cases involve arbitrary and inconsistent application of cost-reporting requirements as well as substandard and poorly organized audit processes.

ASHP has requested that CMS cease disallowances until program technical assistance (TA) has been provided and audit processes have been standardized. ASHP advocates strengthened auditor training and provision of TA specific to pharmacy residency programs, including a comprehensive overview of what CMS deems to be optimal cost accounting processes and procedures.