UCLA GME Moonlighting Policy

UCLA GME Moonlighting Policy

PURPOSE

To establish the protocol and standards by which to ensure the quality and safety of patient care, the quality of trainees’ educational experience, and adequate rest for trainees. Residency training is a full time educational experience, that requires extensive clinical activity and availability to patients at times other than the regular working day. Extramural paid clinically related activities (moonlighting) must not interfere with the resident’s educational performance, clinical responsibilities and/or rest periods.

SCOPE

This policy applies to all UCLA-sponsored ACGME and non-ACGME accredited residency and fellowship programs in all clinical learning environments.

DEFINITIONS

ACGME: Accreditation Council for Graduate Medical Education.

Approved GME Program or Approved Training Program: Approved programs include those residency and fellowship training programs approved by the ACGME, or the American Board of Medical Specialties (ABMS).

Coverage: Coverage is defined as being those situations in which a resident is asked to work within his/her own program to fill a shift for an absent resident or open position. Compensation for coverage is at the discretion of the department and may not be considered salary.

Clinical Experience and Education (CEE): CEE hours are defined as all clinical and educational work hours related to the program; i.e., patient care (both inpatient and outpatient), administrative duties relative to patient care, the provision for transfer of patient care, time spent on in-house call or while working home on clinically-related activities such as the electronic health record and taking call, and other scheduled activities, such as conferences. CEE hours do not include reading done in preparation for the following day’s cases, studying, and research done from home. (ACGME Common Program Requirements)

External Moonlighting: Voluntary, compensated, medically-related work performed outside the institution where the resident is in training or at any of its related participating sites. (ACGME Definition)

Internal Moonlighting: Voluntary, compensated, medically-related work (not related to training requirements) performed within the institution/training site in which the resident is in training or at any of its related participating sites (ACGME Definition)

Professional Fee Billing: Billing for a physician’s clinical services to patients under the Medicare Physician Fee Schedule. (GME Definition)

Resident: Any physician in an accredited graduate medical education program, including interns, residents, and fellows. (ACGME Definition)

POLICY

NOTE: This policy does not apply when a resident is asked to work within his/her own program to fill a shift for an absent resident or open position. This scenario would be defined as coverage. Compensation for coverage is at the discretion of the department and may not be considered salary.

1. Eligibility:

   • Only residents who hold a Post-graduate Training License (PTL) or a permanent license to practice medicine in the State of California, and have completed at least 12 months of post-graduate training are permitted to moonlight.

   • Residents must not be required to engage in moonlighting
   • All residents must comply with the rules of the Department to which they are assigned and will also comply with any applicable ACGME, State or Federal regulations setting limitations on Clinical Experience and Education hours. All trainees are required to accurately record their work hours.
   • It is the responsibility of the resident/fellow to seek approval from the program director if they wish to moonlight.
   • Residents who are on any type of administrative leave will not be approved for or permitted to moonlight and prior permission to moonlight will be suspended during any period of leave.
   • Most residents employed on a J-1, H-1B or O-1 visa are ineligible to moonlight or have further restrictions imposed by the Immigration and Naturalization Service (INS) and must abide by their policies.

2. Maximum Work Hours:

   • All time spent by residents in internal and external moonlighting must be counted toward the 80-hour maximum weekly limit.
   • Residents are responsible for ensuring that the addition of moonlighting activities does not result in a work week in excess of the 80-hour maximum, or result in fatigue which might affect patient care or learning.
   • Residents must have at least eight (8) hours respite time between the end of moonlighting shifts and the start of CEE hours of his/her residency.

3. Program Director Responsibilities:

   • The program director must provide a written or electronic approval using the current residency management system, which shall be maintained in the resident’s electronic demographic file.
   • The program director will monitor resident performance to ensure that moonlighting activities do not interfere with the ability of the resident to achieve the goals and objectives of the educational program, interfere with the resident’s fitness for work nor compromise patient safety. If the program director determines that the resident performance is deficient, the permission to moonlight will be revoked and/or disciplinary actions will be taken.
   • The program director may require detailed information on the timing and level of activity in order to ensure moonlighting does not cause fatigue or interfere with patient care and resident education

4. Additional Regulations Regarding INTERNAL MOONLIGHTING. In addition to all of the policy regulations listed for External Moonlighting, Internal Moonlighting requires the following:

   • Internal moonlighting may only occur within the scope of practice in which any licensed physician, board eligible physician or board certified physician would be eligible to practice (whichever is most appropriate).

   • Trainees may not function in the clinical specialty in which they are training.

PROCEDURE

1. Resident and Clinical Fellow Moonlighting Approval Form must be completed and submitted to the Program Director for approval.

2. Moonlighting Approval must be renewed annually for each different moonlighting location.
3. The Program Director must be informed of any activity changes in Moonlighting, including hours, location, type of activity, and supervisor. The resident must submit a new request using the residency management system and the Program Director must approve any said changes electronically prior to the start of the new activity.
4. Moonlighting requests will not be approved retroactively.
5. INTERNAL MOONLIGHTING: The supervisor for an internal clinical moonlighting opportunity must not be the Program Director or in training program leadership. This supervisor must complete and electronically sign a portion of the Internal Moonlighting Request form prior to submission to GME for approval, including resident eligibility requirements for the requested activity.
6. Any trainee engaged in internal moonlighting must have hospital privileges for the clinical activities being performed within the hospital setting.

FORMS

Resident and Fellow Moonlighting Approval Form

Program Director Internal Moonlighting Request Form

REFERENCES

ACGME REQUIREMENTS (Common Program Requirements VI. F. 5.):

• Moonlighting must not interfere with the ability of the resident to achieve the goals and objectives of the educational program, and must not interfere with the resident’s fitness for work nor compromise patient safety. (Core)
• Time spent by residents in internal and external moonlighting (as defined in the ACGME Glossary of Terms) must be counted toward the 80-hour maximum weekly limit. (Core)
• PGY-1 residents are not permitted to moonlight. (Core)

REVISION HISTORY

Effective Date: 11/30/2017p

Review Date: 11/30/2017

Revised Date: 3/20/2020