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Institutional
Policy Of The Massachusetts General Hospital
Executive Committee On Education And Teaching
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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