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Update on GME Funding for Psychology Internship Training Programs
Action Required
Date: January 30,2001
To: State, Practice Division and APAGS Federal Advocacy Coordinators
State Executive Directors, Psychology Internship Program Directors
From: Marilyn Richmond, Assistant Executive Director for Government Relations, American Psychological Association Practice Organization
Re: Update on GME Funding for Psychology Internship Training Programs
For more information: E-mail
Action:
Earlier this month I announced that the U.S. Department of Health and Human Services (DHHS) had released a new proposed rule that would permit Medicare payment for the costs incurred by hospitals or other Medicare providers for psychology internship training. As promised, I am writing to you again to tell you about the proposed rule in detail and to describe the rulemaking process to finalize the rule. Once the rule is final, qualified psychology internship programs will be able to take advantage of this important funding source.
I am pleased to inform you that the proposed rule may be finalized without any substantive changes. In other words, the rule appears to be clearly drafted and unambiguous, and once finalized will provide funding for those psychology internship training programs that apply and qualify under the rule. You will find enclosed a short summary of the proposed rule. As mentioned in our first action alert, you may also view and download the rule from the U.S. Government Printing Office website at http://www.access.gpo.gov/su_docs/aces/aces140.html
- Go to the web address.
- Scroll down to the table of contents for 2001.
- Retrieve the table of contents for January 12, 2001.
- Look under the Health Care Financing Administration/Proposed Rule Medicare: Clinical Psychology Training Programs 01-910.
You may also wish to view the underlying rule to which the psychology training proposed rule is being attached: Nursing and allied health education programs payment policy, 3357-3376 [01-909]. The publication of this rule immediately precedes that of the psychology training proposed rule in the Health Care Financing Administration section: Rules?Medicare, in the January 12, 2001 Federal Register.
Before a proposed Federal rule is made final (and thereby implemented into law), the public may comment on it. We in the Practice Organization are very appreciative to Nadine Kaslow, Ph.D., Chair of the Association of Psychology Postdoctoral and Internship Centers (APPIC), who has agreed to file a comment on the proposed rule to DHHS during the pending 60-day comment period. Dr. Kaslow's comment letter on the proposed rule will mean that APPIC member internship programs will have a voice in this rulemaking process.
While Dr. Kaslow's letter should suffice, should your internship program decide to comment on the proposed rule, we have enclosed a sample comment letter. Recognize that psychology internship training programs are structured in diverse ways, therefore the sample letter merely offers a guide for your comment letter. DHHS must receive your comment letter by 5 p.m. March 13, 2001. Mail (faxes are not accepted) an original and three copies of your comment letter to the following address:
Health Care Financing Administration
Department of Health and Human Services
Attention: HCFA 1089-P
P.O. Box 8010
Baltimore, MD 21244-1850
I am very encouraged by the excitement that this proposed rule has generated among psychology internship program directors, and we have received a number of very good questions about the rule. The enclosed summary should answer many of these questions. There are a couple of questions, though, that we are not able to answer.
The first question is: ?when does the proposed rule become final so that we can apply for funding?? There are no deadlines in Federal law for making a proposed rule final. Sometime after the 60-day comment period on the proposed rule, DHHS will publish a final rule with its responses to the various comment letters that it received when the rule was proposed. We in the APA will work with DHHS for expeditious finalization for this rule. We hope that it will be made final before the end of the year.
The second question is: ?does my program qualify under this new funding provision?? If your psychology internship program is in a hospital or other recognized Medicare facility provider of services and meets the requirements of the rule, then very likely, your program will be eligible to receive funding. Of course, only DHHS can make that determination, once your program has applied for funding.
Finally, I want to update you on our progress concerning funding for postdoctoral training, which remains one of our primary lobbying goals. We believe that the proposed rule was intended to provide for Medicare reimbursement for psychology internship training. We are currently in discussion with DHHS officials about the need for funding of postdoctoral psychology training. We will continue to work on this funding and will inform you of our progress in the coming months.
Summary of the Proposed Rule
Sample Agency Comment Letter |
