Graduate Medical Education Program Accreditation

As part of our comprehensive services to health care clients, Mintz Levin represents graduate medical education (GME) programs in accreditation-related issues, Accreditation Council for Graduate Medical Education (ACGME) matters, and challenges to adverse Residency Review Committee (RRC) decisions.

We counsel GME programs in academic medical centers and teaching hospitals across the country. Our experience extends across the range of disciplines and specialties in which training is provided under the auspices of ACGME.

Our involvement ranges from general consultation and advice about the accreditation process to far more detailed evaluation and representation in accreditation disputes. We have counseled many GME programs on proper evaluation of data, preparation of Program Information Forms, understanding and complying with the General Competencies, planning for site surveys, avoiding accreditation difficulties, and strategies for maintaining compliance with the Institutional Requirements and Program Requirements published by ACGME.

We also represent GME programs that have been cited as deficient in specific areas by the applicable RRC. Our attorneys review the citations and advise on appropriate courses of action. In some instances, for reasons applicable to a specific program and the types of deficiencies that have been raised, a client’s best interests are served not by pursuing the administrative appeal process, but instead by filing a new set of Program Information Forms. In other cases, we advise programs to diligently pursue the administrative remedies available to them because it can be shown that citations were inappropriately imposed. We have handled numerous GME appeals through both the reconsideration/proposed adverse action and appeal hearing phases.

In addition, Mintz Levin works with teaching hospitals that, for a variety of reasons, wish to modify their commitment to sponsoring graduate medical education programs. This may include combining and/or streamlining programs when institutions merge or consolidate, or deciding to downsize or eliminate residency or fellowship positions or programs for economic or other business reasons. We advise these clients on the relevant ACGME requirements, and often interface with ACGME on their behalf.