This is based on my experience, thus far, as an applicant for the 2012-2013 fellowship year.
About 2/3 of the ACGME-approved H&PM programs have ERAS, set on the December schedule, 18 months prior to the start date, i.e., during R2 for IM. This throws off other specialties that usually apply for fellowships the beginning of their last year of residency.
Some programs are clearly, and in some cases explicitly, specialty-centric, limiting their screening process to applicants from 1 or maybe 2 specialties, despite the fact that the H&PM subspecialty is co-sponsored by 10 specialty boards.
No explicit rejections though, so far.
Familiarity and facility with ERAS appears uneven. Application review and timelines for offering interviews is also variable among programs. Initial phone interviews are fairly common.
There's no Match. It's all rolling. This creates a difficult, disempowering, anxiety-provoking and dilemma-prone situation for applicants, who may be interviewed and even receive offers from some programs, while other programs have not yet even contacted them (and, which programs conceivably might be interested in said applicant, and even offer a position after an interview whenever they actually got around to their official process).
This process needs a common set of deadlines. It needs a Match.