Committee of Interns and Residents (CIR), SEIU Healthcare
Public comment closes October 22, 2026

ACGME is rewriting the rules of residency.
Residents should have a say.

The proposed Common Program Requirements revision could affect resident rest, leave protections, due process, mistreatment safeguards, and enforceable training standards. The official survey is long; this free browser helper handles repetitive navigation, applies carefully reviewed recommendations, and autofills editable comments so residents can participate faster.

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Why this matters

The revision touches protections residents rely on.

01

Fatigue & work-hour safeguards

Work-hour proposals include a rotation-specific 80-hour averaging safeguard, deletion of the eight-hour rest expectation, reduced post-24-hour recovery, and deletion of the every-third-night in-house call limit.

6.29 · 6.30 · 6.31 · 6.37 · 6.38
02

Leave, mistreatment & due process

Explicit protections around appropriate absence, retaliation, safe transportation, misconduct accountability, and grievance or due-process safeguards may become less direct or less enforceable.

1.8.c · 2.1 · 6.17.b · 6.22–6.23
03

Training standards

Important competency and specialty-specific standards may move out of binding requirements or be deleted unless Review Committees affirmatively retain them.

1.6 · 4.3–4.9 · specialty-specific Detail requirements
ACGME describes the proposal as a 43% reduction in Common Program Requirements. It also proposes deleting existing specialty-specific Detail requirements unless Review Committees seek to retain them.
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The extension contains 19 reviewed responses. The positions below are exact; the displayed comment text is representative. Every comment is framed around educational quality, competency development, and the clinical learning environment. The extension selects one of several reviewed wording combinations locally once per survey session, and every comment remains editable in the ACGME survey.

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SupportSupport with additional modificationsDo not support
1.6
Short required rotationsKeep educational and supervisory accountability for shorter participating-site experiences.
Support with additional modifications

I support simplifying administrative requirements where doing so does not weaken educational accountability, but the one-month FTE threshold risks creating a gap for shorter required rotations. A recurring two- or three-week experience can still be an important part of a resident's curriculum, with distinct faculty, supervision, assessment, and learning objectives. ACGME's educational mission is best served when programs remain accountable for the quality of every required experience, not only those lasting a month or more. Please retain a defined mechanism for educational and supervisory accountability at shorter required participating-site rotations, even if that mechanism is streamlined.

1.8.c
Safe transportation when fatiguedKeep an explicit safe-transportation protection for residents too fatigued to drive.
Support with additional modifications

I support flexibility in how programs respond to resident fatigue, but the requirement should continue to guarantee access to safe transportation when a resident is too fatigued to drive. Fatigue protections are not separate from education: residents cannot meaningfully learn, incorporate feedback, or provide safe supervised care when exhaustion impairs attention and judgment. Replacing an explicit transportation requirement with the vague phrase 'safe options' risks making access dependent on local interpretation. Please preserve an enforceable safe-transportation option together with appropriate sleep or rest facilities, while allowing programs flexibility in how those resources are provided.

2.1
Due processKeep explicit grievance, due-process, employment, and non-discrimination protections visible in binding requirements.
Support with additional modifications

I recommend retaining explicit program-director responsibility for grievance, due-process, employment, and non-discrimination protections. Residency is an educational relationship with an unusually large power imbalance: advancement, evaluation, clinical opportunity, and future training can all be affected by program decisions. Residents are more able to engage honestly in feedback, remediation, assessment, and professional development when the rules governing adverse actions are transparent and fair. General reference to Sponsoring Institution policies is less clear than naming these responsibilities directly. Please keep these protections visible in the binding Program Requirements, particularly for suspension, dismissal, non-promotion, and non-renewal.

4.3
ProfessionalismKeep professionalism outcomes and specialty-specific resident protections enforceable.
Support with additional modifications

I support updating the professionalism framework, but core professionalism outcomes should remain binding educational expectations rather than being moved entirely into Guidance. Integrity, respect, accountability, confidentiality, responsiveness to patients, and professional well-being are competencies residents must develop and programs must intentionally teach, model, assess, and remediate. Specialty-specific requirements may also protect the conditions in which professionalism is learned, including reasonable workload and educationally appropriate service demands. ACGME should require Review Committees to affirmatively review and preserve specialty-specific standards that remain necessary for professional development and safe independent practice rather than allowing them to disappear by default.

4.4
Patient care competenciesPreserve specialty-specific patient-care standards and resident safeguards.
Support with additional modifications

I support a clearer Common Program Requirement for patient care, but broad language should not automatically replace specialty-specific standards that define what competent practice actually requires. Patient-care competency develops through appropriately supervised clinical experience, progressive responsibility, sufficient exposure to the specialty's essential conditions and procedures, and meaningful faculty feedback. Some specialty requirements also prevent service demands from displacing those educational experiences. ACGME should require Review Committees to affirmatively determine which specialty-specific standards remain necessary to produce physicians ready for safe independent practice and preserve them rather than deleting them by default.

4.5
Procedural competencyProtect procedural training standards and workload safeguards.
Support with additional modifications

For procedural specialties, a general requirement to provide instruction and assessment is not equivalent to enforceable standards that ensure residents actually obtain the supervised procedural experience needed for independent practice. Procedural competency depends on graduated responsibility, adequate case exposure, direct observation, feedback, and opportunities to perform progressively more complex care. Specialty-specific requirements can also protect those learning opportunities from being replaced by service work that does not advance competency. ACGME should require Review Committees to affirmatively review and preserve procedural standards and training-condition safeguards that remain educationally necessary.

4.6
Medical knowledgeKeep specialty-specific knowledge standards and protected education enforceable.
Support with additional modifications

I support emphasizing instruction and assessment in medical knowledge, but broad Common Program Requirements cannot fully define the knowledge base or educational time required in every specialty. Specialty-specific standards help ensure that residents are taught the content necessary for independent practice and have protected opportunities to learn it through conferences, teaching, study, and integration with clinical experience. Service demands should not be allowed to displace the educational work required to develop mastery. ACGME should require Review Committees to affirmatively review and preserve specialty-specific knowledge and protected-education requirements that remain necessary for competency.

4.7
Practice-based learningKeep essential improvement, feedback, quality-improvement, and evidence-appraisal outcomes enforceable.
Support with additional modifications

I support simplifying duplicative language, but practice-based learning and improvement should remain an enforceable educational responsibility of programs. The ability to identify knowledge gaps, seek and incorporate feedback, set improvement goals, critically appraise evidence, and participate in quality improvement is central to lifelong learning and continuous mastery. These skills do not reliably develop from clinical exposure alone; they require intentional teaching, coaching, assessment, and remediation. ACGME should preserve the essential practice-based learning outcomes in binding requirements while allowing programs flexibility in how they teach and assess them.

4.8
Communication & handoffsPreserve communication, teamwork, interpreter, documentation, and goals-of-care expectations.
Support with additional modifications

I support explicitly emphasizing safe hand-offs, but communication education extends well beyond transitions of care. Residents must learn to communicate with patients and families, work effectively across professions, use interpreters appropriately, consult and teach colleagues, document clearly, and discuss goals of care. These are observable clinical competencies that directly affect both learning and patient outcomes and should be intentionally taught, assessed, and remediated. ACGME should keep the essential communication outcomes in binding Program Requirements while allowing programs flexibility in the specific instructional and assessment methods used.

4.9
Systems-based practiceKeep patient-safety, care-coordination, value, and systems-improvement competencies binding.
Support with additional modifications

I support adding education regarding emerging technologies, but systems-based practice should remain broader than technology adoption. Residents must learn how care is coordinated across systems, how system failures create risk, how to improve patient-safety processes, how cost and value influence care, and how to advocate for patients navigating complex institutions. These competencies are fundamental to practicing effectively within modern health systems and require intentional teaching and assessment. ACGME should preserve the essential systems-based practice outcomes as binding program obligations while incorporating emerging technologies into that educational framework.

6.17.b
Harassment & mistreatmentDo not raise the practical threshold for accreditation accountability when serious misconduct occurs.
Do not support

I support considering how promptly and effectively a program responds to misconduct, but the proposed revision should not make a pattern of mistreatment the practical threshold for accreditation accountability. A single severe episode of harassment, discrimination, abuse, coercion, or other mistreatment can fundamentally disrupt a resident's learning environment, psychological safety, willingness to seek supervision, and ability to engage openly in feedback and education. An educational environment cannot function well when residents reasonably fear mistreatment or retaliation. ACGME should retain an enforceable obligation to maintain a learning environment free from these behaviors while considering effective remediation when determining the appropriate accreditation response.

6.22
Right to appropriate absencePreserve the substantive requirement that residents be allowed appropriate absence when unable to safely work.
Do not support

I oppose deleting the explicit requirement that residents be allowed an appropriate absence when they cannot safely perform clinical responsibilities because of fatigue, illness, family emergency, medical leave, parental leave, caregiver leave, or similar circumstances. Graduate medical education depends on residents being able to participate meaningfully in clinical care, supervision, feedback, and learning; requiring presence when a resident cannot safely function does not create educational value. A policy describing how to request coverage is not equivalent to a substantive requirement that appropriate absence actually be allowed. Please preserve that protection in binding language, either in 6.22 or explicitly within revised 6.23.

6.22.b
Anti-retaliation protectionPreserve the explicit “without fear of negative consequences” protection.
Do not support

I strongly oppose deleting the requirement that absence and coverage policies be implemented without fear of negative consequences. Residents must be able to disclose fatigue, illness, family emergencies, and other circumstances that make safe clinical participation impossible without fearing retaliation for doing so. A learning environment built on supervision and honest communication cannot function if residents are incentivized to conceal impairment or avoid using legitimate leave. The revised requirements should retain an explicit anti-retaliation protection while allowing transparent communication about unavoidable training-duration or board-eligibility consequences associated with extended leave.

6.23
Absence coverage policyA policy should not replace the right to appropriate absence and protection from retaliation.
Support with additional modifications

I support requiring clear absence and coverage policies, but revised 6.23 should preserve the substantive protections currently contained in 6.22 and 6.22.b. A well-designed educational environment needs both a reliable coverage process and a clear assurance that residents may step away when they cannot safely participate in clinical training without retaliation for appropriately doing so. Merely requiring a policy does not guarantee access to an appropriate absence or psychological safety in using it. Please incorporate both the right to appropriate absence and explicit anti-retaliation language into the binding text of 6.23 rather than relying on Guidance alone.

6.29
80-hour averaging within a rotationSupport a rotation-specific averaging window so one assignment cannot offset another.
Support

I support the proposed revision to 6.29 because the 80-hour limit should be evaluated within the clinical assignment where the education and workload actually occur. A fixed four-week averaging window can allow an excessively demanding short rotation to be mathematically hidden by a lighter rotation that follows, even though the resident cannot recover the teaching, reading, feedback, or reflective learning lost during the overloaded experience. Averaging within a single rotation better aligns the work-hour standard with the educational quality of each assignment while preserving reasonable week-to-week flexibility. Please retain the rotation-specific averaging safeguard in the final requirement.

6.30
Eight hours between scheduled periodsOppose eliminating inter-shift recovery that helps residents return ready to learn and provide safe care.
Do not support

I do not support eliminating the expectation for eight hours off between scheduled clinical work and education periods. The purpose of protected time away from work is not only fatigue mitigation; it also preserves the cognitive capacity residents need to learn from clinical experience, read, reflect, incorporate feedback, and return ready for supervised patient care. When recovery time becomes too short, both education and patient safety suffer because residents may be physically present without being able to learn or perform at their best. ACGME should retain a clear expectation for adequate time between scheduled periods rather than removing this educational safeguard.

6.31
Post-call recoveryOppose reducing post-call recovery needed for attention, learning, judgment, and safe patient care.
Do not support

I do not support reducing required time off after 24 hours of in-house clinical work from 14 hours to 12 hours. After a prolonged duty period, residents need meaningful recovery before the next educational or clinical obligation so that fatigue does not convert subsequent training time into low-quality learning and impaired performance. Adequate post-call recovery supports attention, memory consolidation, receptiveness to feedback, professional judgment, and safe patient care. ACGME's goal should be to structure clinical education so residents can actually learn from it, not simply return as soon as the clock permits. Please retain the 14-hour post-call recovery period.

6.37
Night floatKeep Review Committee authority to limit prolonged night-float assignments when specialty needs justify it.
Support with additional modifications

I support removing duplicative language, but Review Committees should retain authority to limit the duration and frequency of night-float assignments when specialty-specific educational needs justify it. Weekly hours alone do not measure what residents lose when prolonged night work separates them from daytime procedures, scheduled conferences, longitudinal faculty mentorship, multidisciplinary teaching, and elective experiences. A schedule can comply with aggregate hour limits while still producing an educationally narrow rotation. ACGME should preserve a specialty-level mechanism to limit night float when its duration or frequency undermines the breadth and quality of training.

6.38
Every-third-night call limitOppose deleting the every-third-night limitation on in-house call.
Do not support

I oppose deleting the every-third-night limitation on in-house call. Weekly-hour limits, days off, and maximum shift duration do not fully capture the educational consequences of very frequent call, including repeated fatigue, fragmented recovery, reduced access to daytime teaching, and diminished ability to reflect on and consolidate learning. The proposed revision also reduces post-24-hour recovery and removes the eight-hour inter-shift expectation, so eliminating another independent safeguard creates a cumulative concern. If more frequent call is already nearly impossible under other rules, retaining the explicit limit provides educational and scheduling clarity at little cost. Please preserve the every-third-night limitation.

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