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No Link Between Department of Education Recognition And Medicare Pass-Through Payments

There remains considerable confusion concerning which Clinical Pastoral Education training programs qualify to receive Medicare Payments. The leadership of the Association for Clinical Pastoral Education has not acted in a responsible manner to clear up the misunderstanding; promoted by ACPE leaders; that only ACPE accredited Doe recognized programs qualify for such payments. Clinical Pastoral Education training programs accredited by The College of Pastoral Supervision & Psychotherapy also qualify for such payments. Medicare officials do not support the ACPE only claim. We quote a response provided from the Medicare office: “The regulations cite the ACPE as an example of a national professional organization that would be sufficient as the accrediting body. However, the regulation at section 413.85(e) also specifically state that the accrediting bodies are “not limited to” the cited organizations. While programs that are accredited by the ACPE meet CMS definition of an Approved Nursing and Allied Health Education Program, there is no exclusivity granted by the regulations to ACPE programs.”

By George Hankins-Hull Th.M., Dip.Th.
Diplomate in Clinical Pastoral Supervision
This document provides an overview of the Medicare final rule for the inpatient prospective payment system (PPS) for the federal fiscal year (FY) 2004, as it pertains to Nursing and Allied Health Education and in particular to Clinical Pastoral Education.
The final rule is available electronically on the Federal register website at and by selecting the entry under Centers for Medicare & Medicaid Services. The provisions of this rule go into effect 10/01/03 Questions regarding the summary or the final rule as it pertains to clinical pastoral education can be directed to George Hankins-Hull.

Continuing Education Issue for Nursing and Allied Health Education: The Centers for Medicare & Medicaid Services (CMS) has revised regulations to clearly differentiate between provider-operated continuing education programs that CMS considers normal hospital operating costs covered by the Prospective Payment System (PPS) rate, and approved Nursing and Allied Health Education programs (NAHE) that are eligible for pass-through payments. CMS is amending the regulations to state that activities treated as normal operating costs include "Educational seminars, workshops, and continuing education programs in which the employee participate that enhance the quality of medical care or operating efficiency of the provider and, effective October 1, 2003, do not lead to the ability to practice and begin employment in a nursing or allied health specialty." These types of programs will not be paid as pass-through.

Pass-through payments will be provided only to programs that qualify an individual to be employed in a specialty in which the individual could not have been employed before completing a particular education program. Industry norm will be defined to mean that more than 50% of hospitals in a random, statistically valid sample require the completion of a particular training program before an individual may be employed in a specialty. CMS provides the following as examples of the application of this criterion:

  • Participants in a provider-operated nursing diploma program could not practice as nurses without that training. Therefore, the nursing program may be eligible for pass-through payment.

  • A nurse residency program is a postgraduate program that typically lasts one year and trains nurses to care for patients who require complex services. CMS states that these programs do not qualify the nurse to be employed in a new specialty and are not eligible for pass-through payment.

  • A one-year pharmacy practice residency is typically required before a hospital will hire an individual to fill a position that requires direct contact with hospital patients. CMS considers this the industry norm for practice in the "specialty" of hospital pharmacy. Therefore, these programs may be eligible for pass-through payment.

  • Pharmacists may also go on to participate in a second year of specialized residency in a focused area of pharmacy practice such as oncology or cardiology. CMS has determined that it is NOT currently the industry norm to require completion of these programs before beginning work in these specialties. Therefore, these programs are not eligible for pass-through payment. This could change if it later becomes the industry norm to require this training.

It is the industry norm for hospitals to employ only board-certified chaplains and to require completion of approximately 1,600 hours of Clinical Pastoral Education (CPE) before an individual can begin employment as a hospital chaplain. Therefore, a hospital that operates a CPE program may be eligible for pass-through payment.

To receive pass-through payment, an eligible program must meet all other criteria including: the program must be accredited by a national approving body; and the provider must directly incur the training costs, have direct control of the curriculum and administration of the program, employ the teaching staff, and provide and control the classroom training and clinical instruction.

CMS will consider an activity an approved nursing and allied health education program if the program is a planed program of study that is licensed by the State law, or if licensing is not required, is accredited by the recognized national professional organization for that particular activity. Such national accrediting bodies include, but are not limited to, the Commission on Accreditation of Allied Health Education Programs, the National League of Nursing Accrediting Commission, the Association for Clinical Pastoral Education Inc., and the American Dietetic Association.

Board Certification of Chaplains: CMS understands that "board-certification of chaplains is carried out by nationally recognized organizations that are part of the Commission on Ministry in Specialized Settings (COMISS), an umbrella network for pastoral care organizations that share the same standards of educational preparation and clinical training."

The College of Pastoral Supervision & Psychotherapy is a nationally recognized professional pastoral care training, certifying and accrediting organization. CPSP is a member organization of COMISS and accredits a wide range of training programs in clinical pastoral education, pastoral counseling, and pastoral psychotherapy.

CPSP programs meet or exceed generally accepted standards of training for pastoral counselors, institutional chaplains, and pastoral psychotherapists. CPSP programs also meet traditional seminary requirements for candidates seeking graduate theological degrees as well as minimal standards set by various denominations and governmental agencies.

CPSP programs are designed to prepare persons for credentials as Pastoral Counselor, Board Certified Clinical Chaplain, Board Certified Associate Clinical Chaplain, Dipolmate in Pastoral Supervision or Diplomate in Pastoral Psychotherapy

CPSP accredited training programs meet CMS criteria as it pertains to Nursing and Allied Health Education and in particular to the training of Board Certified Chaplains. CPSP accredited Clinical Pastoral Education training programs are eligible to receive pass-through payments on the basis that: It is the industry norm for hospitals to employ only board-certified chaplains and to require completion of approximately 1,600 hours of Clinical Pastoral Education (CPE) before an individual can begin employment as a hospital chaplain. Therefore, a hospital that operates a CPE program may be eligible for pass-through payment.

George Hankins Hull

Director of Pastoral Care & Clinical Pastoral Education

University of Arkansas for Medical Sciences

4301 W. Markham St., #561

Little Rock, AR 72205

Telephone (501)-686-6888

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