The AAMC's comments will be limited to a discussion of the Academic Medical Center exception. The AAMC is very pleased that the Health Care Financing Administration recognizes the unique organizational structures of AMCs, the importance of their missions, and the value of an exception tailored to their needs. The comments below discuss those provisions that the AAMC has identified as needing clarification or changes. The Referring Physician 1. II.4. of this letter, this proposed change also requires that the regulation provide an alternative definition of an academic medical center.
Some community hospitals have very large graduate medical education programs.
While many faculty physicians have appointments at the affiliated medical school, other faculty physicians have bona fide appointments from the academic medical center itself. The final rule has a number of requirements regarding the referring physician's total compensation for the previous 12-month period. These requirements raise several issues that will be addressed below. However the AAMC first would like to suggest an alternative approach to compensation paid to referring physicians. Even if HCFA chooses not to make the compensation requirements for academic physicians consistent with those of other bona fide employees, it is imperative that the final regulatory language makes clear that productivity bonuses for AMC physicians are not prohibited.