ASAM Submits Comments on CMS Proposed Rule Establishing Application Process for New Medicare-Supported GME Positions

On June 22, ASAM submitted comments in response to a proposed rule from the Centers for Medicare and Medicaid Services (CMS) intended to implement certain provisions of the Consolidated Appropriations Act (CAA) of 2021, as well as update various Medicare payments and rates. ASAM's comments focused on CMS' proposed implementation of a provision of the CAA which created 1,000 additional Medicare-supported graduate medical education (GME) positions.  

Specifically, ASAM urged CMS to prioritize hospitals that either have, or are developing, training programs in addiction medicine or addiction psychiatry during the application process. ASAM additionally noted that while the Health Professional Shortage Area (HPSA) designation serves as an objective criterion for establishing whether the additional residency slots would benefit underserved populations, it may not fully identify geographies and patient populations lacking access to addiction treatment specifically. Therefore, CMS can most effectively improve access to addiction treatment by prioritizing hospitals that either have, or are developing the aforementioned training programs. CMS should also collaborate with the Health Resources Services Administration (HRSA) to define and designate substance use disorder (SUD) HPSAs so that these residency positions and other funding opportunities can be better targeted to underserved areas with high SUD and overdose burdens but limited treatment access.

Finally, ASAM  objected to the proposal to limit applications from hospitals in mental health-only shortage areas to psychiatry residency programs. Physicians who are board-certified in addiction medicine are a key component of the mental health workforce, and they are trained to provide comprehensive bio-psycho-social care to patients with addiction. Accordingly, ASAM urged CMS to accept and prioritize applications for any primary residency program from hospitals that either have, or are developing, training programs in addiction medicine in mental health-only shortage areas as well. 

Read the comment letter here.

Read the proposed rule here.

Read the proposed rule fact sheet here.