Intern and Resident Information System (IRIS)

Teaching hospitals are required to send in IRIS files as part of their cost report. These files contain a list of interns and residents being trained at that provider, as well as their assignment periods, and are used as supporting documentation for the Full Time Equivalent (FTE) counts claimed in the cost report, which form the basis for Direct Graduate Medical Education (DGME) and Indirect Medical Education (IME) reimbursement. CMS maintains an internal IRIS system that validates IRIS files sent in by providers and is used to identify overlaps where multiple hospitals end up claiming reimbursement for the same resident. CMS also maintains documentation for providers filling out their IRIS submissions.

There are a number of third-party vendors that offer software for creating IRIS files, which providers are encouraged to use. CMS offered IRIS legacy system (IRISv3) is now retired.

For Fiscal Years Beginning (FYBs) prior to October 1 2021, the legacy IRIS DBF file format, defined by the IRISv3 and IRISEDv3, may be utilized to format an IRIS file.

For FYB’s beginning on or after October 1, 2021, providers and vendors are required to utilize the new XML format to create an IRIS file.

IRIS Overlap Duplicate Full-Time Equivalent (FTE) Reviews

An intern and resident (I&R) overlap occurs when two or more providers claim the same resident for some period of time at a combined total of more than 100% utilization. A significant percentage of providers participating in the DGME and IME programs have FTE overlaps and will be subject to review. All cost reports with fiscal years ending on or after 2017 will be subject to the FTE duplicate reviews. 
 

The IRIS FTE Duplicate Review Contractor is Myers and Stauffer LC, conducting these reviews on behalf of CMS.  Impacted providers will receive an IRIS information request letter from the contractor informing them that I&R rotation overlaps have been identified in their IRIS records. Providers will be required to respond within 30 days, providing the information and documentation requested in the letter to support their claimed time for all overlapping rotations.  
 

These reviews are in addition to any cost report audit activities completed by the Medicare Administrative Contractors (MACs). Myers and Stauffer LC will work closely with the servicing MACs to determine if any I&R overlaps have been previously resolved.  Any adjustments resulting from the overlap reviews completed by Myers and Stauffer LC will be incorporated in cost report settlements completed by the MACs.   The CMS will issue reopening letters to providers to review duplicate interns and residents FTEs for all impacted final settled cost reports from fiscal year 2017 and later that are still within the three years reopening period.

Follow the links below for additional information.