As I shared in my blog post in November, federal auditors have been enforcing confusing requirements on PGY1 residency programs, leading to funding clawbacks by the Centers for Medicare & Medicaid Services (CMS). Auditors for the Medicare program have claimed that some standard hospital business and training practices are noncompliant, despite a lack of clear guidance from the agency.

ASHP met several times with CMS staff to discuss the arbitrary nature of these audit findings and the frustrating lack of guidance to help residency program sponsors meet CMS’ expectations. We also enlisted help from supporters in Congress. Despite this advocacy, CMS still refuses to provide the level of guidance our programs deserve.

ASHP and our supporters in Congress will continue to push the agency to provide guidance to residencies. But today, I want to make clear that residency program sponsors should not wait to modify their program operations to reduce the risk of funding clawbacks.

ASHP has launched a new residency toolkit to help PGY1 programs comply with program requirements and avoid adverse audit findings. I urge residency program directors to review this toolkit and identify opportunities to reduce audit risks in their own programs.

This toolkit recommends steps programs can take to prepare for CMS audits and reduce their risk of funding clawbacks. We have created these resources based on feedback from residency programs that have undergone recent compliance audits.

This resource is the latest in ASHP’s advocacy efforts to protect PGY1 residency funding and request clear guidance from CMS on compliance requirements.

We will continue our work to protect residency funding. However, we ask for your help. Please undertake a critical evaluation of your program based on the guidance in our residency toolkit and alert ASHP’s government relations team if you are undergoing program audits.

Pharmacy residencies are essential for patient care and even required for specialty positions. We must work together to ensure federal funding for these programs is protected for years to come. Our patients deserve it.

Thank you for all you do for our patients and our profession.

Sincerely,

Paul

Posted on April 18, 2024