The transition to a single accreditation system (SAS) is well underway, and teaching hospitals and residency program sponsors are scrambling to understand all the implications for their programs. One area of confusion that has sparked client questions in recent months involves the status of the American Osteopathic Association (AOA) as a Medicare-approved accrediting body. Specifically, under the SAS, programs that formerly were AOA-accredited are being required over the next couple of years to transition to become accredited instead by the Accreditation Council for Graduate Medical Education (ACGME). This migration has caused many to question whether AOA-approved programs are still "approved medical residency training programs" for Medicare GME payment purposes during this transition period. Rest assured: They are!

Irrespective of this reshuffling of responsibilities among these two large accrediting bodies, the Medicare statute and regulations define what constitutes an "approved" program, and those definitions have not changed. Thus, as defined for Medicare GME payment purposes, an approved program generally is one that, among other possibilities, has either been accredited by one of four specific accrediting bodies expressly enumerated in the applicable regulations:(i) ACGME, (ii) AOA, (iii) the Commission on Dental Accreditation (CODA) or (iv) the Council on Podiatric Medical Education (CPME); or, alternatively, one that counts towards certification in a specialty or subspecialty recognized by the American Board of Medical Specialties (ABMS). The Medicare statute includes a similar list.

The key point is this: The above list of Medicare-recognized accrediting and approval bodies has not changed. AOA remains a Medicare-approved organization for purposes of accrediting "approved" medical residency programs for GME payment purposes, irrespective of the movement towards the SAS.

Clients also have asked whether AOA's Medicare-approval is being revoked, or will otherwise terminate, effective July 1, 2020, which is the full implementation date for the SAS, at which point all formerly AOA-accredited programs will have been (and must be) migrated completely to ACGME. The answer is no, unless and until Congress revises the statute and CMS revises its regulations. In order for AOA's accreditation authority to be revoked for Medicare purposes, the applicable Medicare statute and regulations would need to be modified to officially remove AOA from the list of Medicare-recognized accrediting bodies.

All of which is to say that the Medicare payment regulations may not necessarily align with the actual practices of the various accrediting bodies. It is important to keep in mind that it is the Medicare program rules that govern GME payments.