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Because residency education is a full time endeavor, residents
and ACGME fellows must ensure that moonlighting does not interfere
with their ability to achieve the goals and objectives of their
educational Program. Residents and fellows are responsible for ensuring
that moonlighting and other outside activities do not result in
fatigue that might affect patient care or learning. Residents and
fellows are responsible for complying with their Program Duty Hours
Policy. The latter must be approved by the Graduate Medical Education
Committee, and it must be consistent with the UCSF Policy on Duty
Hours. Note: The ACGME requires Program Director pre-approval of
all moonlighting activity by residents and ACGME fellows (http://www.acgme.org).
Each training Program (residency and ACGME fellowship) must develop
a policy regarding moonlighting. The Program’s moonlighting
policy must be developed by the Program’s faculty members
with input and approval by the Program Director and the Department
Chair. Trainees should be involved in this process. The Program
must state whether moonlighting is or is not allowed (both internal
to UCSF and external to UCSF). If moonlighting is allowed, the policy
must contain a method for written pre-approval, monitoring and periodic
review. The policy may be more restrictive but may not be less restrictive
than the UCSF institutional policy. Trainees must not be required
to engage in moonlighting, and this must be stated in the policy.
Each Program’s moonlighting policy must be approved by the
Graduate Medical Education Committee (GMEC). The Program must demonstrate
ongoing compliance with Duty Hours as a prerequisite for GMEC approval
of a Program policy that allows moonlighting.
It is the responsibility of the residents/fellows to obtain written
permission to moonlight from the Program Director prior to beginning
the moonlighting activity. This is true both for “internal”
and “external” moonlighting (see definitions below).
An approval template form is attached. This template indicates minimum
information; Programs may elect to require more information. (Please
note that pre-approval is required by both the ACGME and UCSF).
The Program Director will monitor resident performance in the Program
to ensure that moonlighting activities are not adversely affecting
patient care, learning or resident fatigue. If the Program Director
determines that the resident’s performance does not meet expectations,
permission to moonlight will be withdrawn. Monitoring information
will be reviewed periodically with the Program’s Teaching
Committee. The GMEC will periodically review reports by the Program
Directors regarding moonlighting activity.
Any resident/fellow moonlighting without written pre-approval will
be subject to disciplinary action.
“Internal moonlighting” is defined as extra work for
extra pay performed at a site that participates in the resident’s
training Program. This activity must be supervised by faculty and
is not to exceed the level of clinical activity currently approved
for the trainee. While performing internal moonlighting services,
trainees are not to perform as independent practitioners. Internal
moonlighting hours must be documented, and they must comply with
the written policies regarding Duty Hours as per the training Program,
UCSF and ACGME.
“External moonlighting” is defined as work for pay
performed at a site that does not participate in the resident’s
training Program. External moonlighting hours must be documented
(including days, hours, location, and brief description of type
of service(s) provided) in order to comply with Medicare reimbursement
requirements for GME. For external moonlighting, the trainee is
not covered under the University’s professional liability
insurance Program as the activity is outside the scope of University
employment. The trainee is responsible for his/her own professional
liability coverage (either independently or through the entity for
which the trainee is moonlighting), DEA licensure, Medicare (or
other governmental) provider number and billing training, and licensure
requirements by the California Medical Board and any other requirements
for clinical privileging at the employment site.
ACGME fellows may moonlight at a UCSF School of Medicine facility
if it is outside the area of training for that fellowship and if
it is not in an in-patient setting (per Medicare rules). A “Professional
Services Agreement for Moonlighting by ACGME Clinical Fellows”
form must be completed and signed prior to moonlighting at a UCSF
facility by an ACGME fellow. This would be considered Internal moonlighting
because it is at a site used by the training program. Note: If the
ACGME fellow is working within his/her training program, not exceeding
his/her approved clinical level of activity and is supervised by
faculty, the “Internal Moonlighting Form for Residents”
should be used (http:www.medschool.ucsf.edu/gme).
Approved: GMEC 9/20/04
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