Specifically, since 2019, pharmacy residency programs across the country have been hit with arbitrary cost disallowances on the basis of cost accounting procedures that had been acceptable in previous years and/or to different auditors, despite the fact that there have been no regulatory changes to the funding mechanism.

Medicare Administrative Contractors (MAC) have disallowed costs based on details such as off-site rotations (a staple of residency programs), and the name on a program’s diploma/certificate. 

Many of these cases involve arbitrary and inconsistent application of cost-reporting requirements. CMS staff have verbally acknowledged that the factors MAC auditors have used to challenge residency funding are inconsistent with CMS’ intent, yet the Agency has failed to provide clarifying guidance in writing.

Congress has introduced legislation that would prevent these unnecessary funding clawbacks that jeopardize pharmacy residency programs. 
Congress has introduced bipartisan legislation to protect critical federal funding for pharmacy and nursing residency programs. The Rebuild America’s Health Care Schools Act of 2025 (S. 1087/H.R. 1708) would clarify the requirements that hospitals and health systems must meet to receive Medicare reimbursement for operating healthcare residency programs, including pharmacy residency programs.

Take action now to send an email asking your members of congress to cosponsor these important bills! For more information, please contact ACCP’s team in Washington, DC at jmcglew@accp.com.