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Re: Credentialling Categories For Trainees

These categories should be used for GME trainees who will be performing clinical activities. For simplicity the phrase "ACGME programs" is used to refer to programs approved by ACGME, the American Board of Medical Specialties or other national accreditation bodies.

Category Billing to Medicare/
Medicaid in the Trainee's Name
Billing to Other Payors Admitting Privileges
 
Resident No No No
MGH appointment title: "Resident"
All Residents (i.e., House Officers) are in ACGME training programs and cannot bill in their own name. Residents work under the supervision of attending physicians, and do not serve as the physician-of-record. (Where applicable physical presence and documentation standards are met, attending staff may bill within HCFA’s guidelines for billing by teaching physicians.)
 
Chief Resident "A" No No No
MGH appointment title: "Chief Resident"
Chief Residents who are still completing residency requirements in ACGME programs for primary board eligibility
cannot bill and cannot admit under their own name. (Where applicable physical presence and documentation standards are met, attending staff may bill within HCFA’s guidelines for billing by teaching physicians.)

Note: These individuals can use the title "Chief Resident" on CVs or other documents even if their appointment title is "Resident", as long as the Service Chief has given them the Chief Resident designation.
 
Chief Resident "B" Yes Yes Yes
MGH appointment title: "Assistant in [Specialty]"
Chief Residents who are board-eligible or board certified in the specialty in which they practice are no longer trainees. These Chief Residents are not enrolled in an ACGME program, are fully licensed and have billing and admitting privileges.

Note: These individuals can use the title "Chief Resident" on CVs or other documents even if that title is not contained in their appointment, as long as the Service Chief has given them the Chief Resident designation.
 
Trainees "moonlighting" at Partners institutions Yes Yes/No* No
MGH (secondary) appointment title: "Graduate Assistant"1
This category refers to those Residents and Fellows who are enrolled in an ACGME training program, but who also engage in clinical activities that are outside the scope of their training program (i.e., "moonlighting") at a Partners site. NOTE: This appointment category is not relevant to the moonlighting that trainees may do on their own outside the Partners institutions.

At MGH appointment as a "Graduate Assistant" is used as an additional, secondary appointment for trainees in ACGME programs (or for Research Fellows) where it is appropriate for billing to be done in the trainee’s name for "moonlighting" activity that is clearly outside the training program.

Note: These individuals must be fully licensed and arrange for extension of their CRICO coverage. Bills can be issued in their name only for outpatient services, including the emergency department. A written moonlighting agreement must be in place in order for bills to be submitted in any trainee’s name who is enrolled in an ACGME program, even if: (a) a secondary appointment with admitting/billing privileges was previously approved for the individual, or (b) a subspecialty trainee is working in a specialty in which s/he is already board certified. The form of such agreements must be approved by the Partners Office of the General Counsel.
 
ACGME Fellow No Yes/No* No
MGH appointment title: "Clinical and Research Fellow"2
As trainees, these Fellows in ACGME programs cannot admit or bill government programs in their own name, except as noted above (the "moonlighting exception"). (As above, attending staff may bill within HCFA’s guidelines for billing by teaching physicians where applicable physical presence and documentation standards are met.) At MGH, an additional secondary appointment as a "Graduate Assistant"1 may be required for credentialling by the payor.

Note: There may be circumstances where these ACGME Fellows can, if fully licensed, be credentialled by some managed care entities or other payors for bills to be issued in their own name; this does not apply to Medicare/Medicaid. On a case-by-case basis, a department may seek authorization for an ACGME Fellow to bill non-government payors from the Billing Compliance Officer(s) of the applicable hospital and physician group.
 
Non-ACGME Fellow "A" No No No
MGH appointment title: "Clinical and Research Fellow"2
These non-ACGME Fellows are limited to a Fellow appointment, without admitting or billing privileges, if they are not board eligible, not fully licensed, or lack approval for a staff appointment from their Service Chief.
 
Non-ACGME Fellow "B" Yes Yes Yes
MGH appointment title: "Assistant in [Specialty]"
Though clinical Fellows in non-ACGME programs are generally regarded as trainees, they are gaining clinical experience where additional subspecialty certification is not available. For those Fellows who are board certified (or eligible) in the specialty they practice and are fully licensed, it is appropriate for them to admit and for their services to be billed in their own name, if the Service Chief deems them competent to function without supervision.

Note: "Staff" appointments in this category will be short-term; no commitment of long-term employment is implied by the institution.

*depending on payor credentialling requirements

1) Graduate Assistant: An individual who is fully licensed, has completed residency or other professional training requirements, and whose assignments are temporary and limited by the Chief.

2) Individuals who are not enrolled in a GME training program may also be appointed as Clinical and Research Fellows.

Approved by ECOTE 4/6/98
Approved by Chiefs’ Council 4/15/98
Approved by GEC 5/27/98

 
 
 
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Last Updated:
01/10/09
 


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