Keeping track of, and subsequently auditing, these costs would require detailed information on residency training years and specific specialties. A cost accounting infrastructure capable of documenting these costs is virtually unimaginable. At a minimum, current longstanding infrastructures would be greatly compromised. The proposal has the potential to seriously impede resident training in nonhospital sites. The Association believes that the proposed change could undermine the current relationships between hospitals and nonhospital providers and impede resident training in nonhospital settings.
Resident training occurring in community-based physician practice offices is of particular concern.
These offices currently constitute a substantial source of ambulatory training sites and their use will grow as curriculum and accreditation entities add additional ambulatory care training to their requirements. The administrative burden that would be imposed on physicians under HCFA's proposal could seriously undermine the desire of these community-based physicians to educate residents. Many do not have the accounting and administrative infrastructures that would be required by the proposed rule. As one example, the proposed rule would require physicians to document the precise number of hours they spend teaching or supervising. These demands place an additional burden on physicians whose current workloads are increasingly dominated by documentation requirements.