NACHC Provides Feedback on Proposed Revisions to ACGME Institutional Requirements

The Accreditation Council for Graduate Medical Education (ACGME) is a national organization that determines educational standards for training physicians in various specialties such as family medicine, pediatrics, psychiatry and obstetrics and gynecology after they graduate from medical school. Such specialty training programs are also known as residencies.

Community Health Centers that serve as residency training sites through the Teaching Health Center Graduate Medical Education (THCGME) program or otherwise must abide by these standards to maintain accreditation, which can be a daunting task for smaller health centers with limited resources. Through the recently launched NACHC THCGME Task Force, health center leaders in GME asked NACHC to advocate with ACGME to ensure Community Health Centers can successfully train the next generation of the primary care workforce.

The ACGME periodically updates the standards they publish after inviting feedback through a public comment process. Most recently, ACGME was accepting comments on proposed revisions to their requirements for Sponsoring Institutions (SI) that are responsible for ensuring all aspects of physician residency training in their program meets ACGME's requirements. NACHC submitted comments on these revisions expressing support for elements that would improve the quality of training and physician wellbeing while providing constructive feedback on aspects that could hinder health center-based residency program operations. NACHC's comments are summarized below:

• NACHC commended ACGME efforts to enhance oversight of training standards at clinical sites and requested greater clarity on how a proposed requirement for only assigning trainees to sites that facilitate patient safety and care quality efforts would be implemented at programs that include training at Community Health Centers. NACHC asked ACGME to ensure redundant requirements do not inadvertently lead to duplication of effort that does not yield better outcomes.

• We noted that health center-based residency programs often rely on clinical learning environments that are distributed across multiple organizations and sites. Thus, it may not be feasible for a leadership team at just one Primary Clinical Learning Environment (PCLE) to be responsible for overall GME strategy. We suggested ACGME consider improving GME strategic oversight by requiring a leader from the PCLE to serve on the GME Committee overseeing the program and ensuring a diversity of perspectives is represented on the Committee. On a similar note, we expressed reservations about requiring Designated Institutional Officials (DIO) from having to hold an executive leadership role at the PCLE as this arrangement can be impractical to implement in training consortia comprising of Community Health Centers and other organizations.

• On the other hand, NACHC conveyed support for increased institutional support (including increasing salaries) for DIOs, administrators and other GME leaders, which might be scaled up based on the size and scope of oversight required. NACHC noted that without increasing administrative support, ACGME's proposed revisions that would require increased analysis and reporting of organizational finances would be an undue burden on Community Health Centers, which have limited resources and operate on thin margins. Additionally, NACHC advised ACGME that requiring bylaws updates to rapidly be implemented at clinical sites such as health centers participating in a training consortium may not be feasible as participating organizations may have significantly different processes and timelines for bylaws updates.

• NACHC also expressed agreement with ACGME's proposal to enhance protections for residents who might be exposed to disruptions in training as it would protect the wellbeing of trainers, trainees and other staff at health centers alike. Similarly, NACHC endorsed another initiative to improve residents' training in diversity, equity and inclusion, but cautioned ACGME to avoid duplicating training at multiple sites covering the same content.

Overall, NACHC thanked ACGME for this opportunity to contribute feedback on proposed revisions to its institutional requirements and connected with ACGME to collaborate on future opportunities for improving the quality of residency training at Community Health Centers. If you would like more information about NACHC's submitted comments and other engagement on workforce development, please contact [email protected].