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GRADUATE TRAINEE MOONLIGHTING POLICY Policy
regarding professional activities outside the scope of the educational
program (attachment to contract issued to graduate trainees)
Note: Those sections of this policy highlighted in bold italics
apply specifically to graduate trainees in programs accredited by
the ACGME (Accreditation Council for Graduate Medical Education).
This policy addresses professional activities that you may undertake
as a physician that are outside the scope of your graduate medical
education program, hereinafter referred to as "moonlighting".
As a graduate trainee, your training experience and responsibilities
must have your highest professional priority at all times.
All clinical trainees must be available, alert and fully responsive
and responsible for all of their clinical and training activities
at the Hospital(s); no activities outside the scope of the training
program should interfere with these learning opportunities and their
attendant service responsibilities.
Given the clear priority of training, the leadership of each program
decides whether its training requirements are compatible with any
professional activities outside the scope of the training program.
The Chief of Service has the right to prohibit all types of moonlighting
for his/her trainees.
Activities outside the scope of the training
program:
Work within the institution (as well as at other health care institutions)
is considered moonlighting if it is not part of your residency or
fellowship program and is therefore optional and separately paid.
This definition pertains even if the work is supervised by attending
physicians and even if it is identical to activities that are part
of your residency or fellowship program.
Moonlighting cannot be required of you by
your program director or Chief of Service.
If you wish to engage in such activities and your Chief does not
prohibit participation in such additional professional activities,
you must accomplish the following steps:
- You must obtain a full Massachusetts medical
license.
- Prior to accepting any moonlighting responsibilities, you must
submit to your Chief and/or program director in writing a letter
listing the institutions for moonlighting activities, the scope
of the proposed activities and the maximum number of hours (per
week and per month) of proposed moonlighting (template provided
below).
- You must receive from the Chief and/or program
director a signed copy of the letter, indicating permission to
proceed.
- It is the responsibility of the moonlighting trainee to update
this letter (and have it signed again by the Chief and/or Program
Director) when necessary to reflect proposed changes to the number
of hours spent in moonlighting activities and/or the sites where
moonlighting occurs.
- It is the responsibility of the program director
to ensure that a copy of this letter is kept in your file, as
required by the ACGME.
- No outside professional activities may be undertaken during
the weekday hours of 8:00 a.m. to 6:00 p.m. (except during vacation
periods) without the express written permission of the Chief and/or
program director.
4. You must arrange for your own malpractice insurance
to cover professional activities outside the educational program
through: (a) the institution at which you will be moonlighting;
(b) Promutual; or (c) extension of your CRICO insurance, which may
be approved in specific circumstances as described below.
If you are permitted to engage in professional
activities described as moonlighting, you should be aware that the
effect of these activities upon your performance in the training program
will be monitored; any adverse effects may lead to withdrawal of permission
to moonlight by your training program director or Chief of Service.
You should be aware that, under Massachusetts Board of Registration
in Medicine regulations, you will be required to list on your Hospital
re-appointment application form all health care facilities at which
you have provided any patient care over the previous three years.
Please note: In addition to the parameters
outlined in this policy, most residents and fellows 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. See
last section below for details.
Authorized use of CRICO Malpractice
Insurance:
You are generally covered for malpractice through the Controlled Risk
Insurance Company (CRICO) only for activities performed
within the scope of your formal training program at the Massachusetts
General Hospital, the Brigham and Women’s Hospital and defined
affiliates. CRICO will extend coverage in some specified circumstances.
You must refer to the CRICO Insurance Manual for details and must
comply with the required procedures for extending coverage.
PGY-1 and -2 Residents:
CRICO will not extend malpractice insurance
for PGY-1 or PGY-2 interns/residents.
PGY-3 Residents:
If your Chief/program director authorizes you to moonlight, you may
request that your CRICO malpractice insurance cover such professional
activities outside the scope of the educational program.
Moonlighting within the Harvard medical
system:
CRICO coverage requires that there is an exchange of letters between
the Chief of Service at the institution where the resident is scheduled
for malpractice insurance and the Chief of Service where the resident
plans to moonlight.
Moonlighting outside the Harvard medical
system:
The following additional criteria articulated by CRICO must be met:
- There must be an exchange of permission letters between the
Chiefs of Service at the training institution and the moonlighting
site(s);
- A moonlighting waiver form and checklist must be signed by your
Chief “for each rotation during which extended coverage
is requested”;
- You may moonlight “only during research rotations, subspecialty
rotations and other rotations with lighter clinical call.
Residents who moonlight during research rotations must remain
on the schedule of insured physicians maintained by the Named
Insured”;
- You “may not moonlight in an emergency room outside the
Harvard medical system unless enrolled in the Harvard Affiliated
Emergency Medicine Residency Program. If a resident is enrolled
in this program, the guidelines stipulated for fellows will apply.”;
- You “may not exceed the maximum number of hours per week
that the [resident’s] hospital has defined….”;
- You must fully complete and sign the “3rd year resident”
waiver form and complete the application procedure as defined
in the CRICO Insurance Manual.
PGY-4 (and above) Residents:
As above for PGY-3 residents, except that numbers 2, 3 and 6 under
“Moonlighting outside the Harvard medical system” do
not apply.
Fellows:
CRICO insurance coverage may be extended to fellows for services
outside the scope of their hospital training, within or outside
of the Harvard medical system, with the express written approval
of the Chief of Service as evidenced on the appropriate waiver form.
Additional criteria apply for fellows moonlighting in emergency
rooms outside of the Harvard medical system; please consult the
CRICO Insurance Manual for details.
Note: The above requirements apply only to moonlighting at Massachusetts
hospitals. CRICO may cover moonlighting outside of Massachusetts
in some circumstances; please check the CRICO Insurance Manual for
details.
Moonlighting information for International Medical Graduates
(Holders of F-1, J-1, H-1B or O-1 Visas):
- F-1-Practical Training: Eligible to moonlight.
- J-1-Exchange visitor: Activity and/or compensation outside the
defined parameters of the approved residency or fellowship training
program is not permitted.
- H-1B: Employer-specific and limited to the position and duties
included in the employer's application to INS. The H-1B visa application
may include services provided at multiple locations, provided
that the application includes mention of said multiple locations.
Employment with a separate employer (i.e., most moonlighting)
exceeds a typical H-1B application. An outside employer who wishes
to employ a "moonlighter" must file an application with
INS to employ the resident or fellow.
- O-1-Alien of Extraordinary Ability: See restrictions described
for the H-1B visa.
Template Letter Between Graduate Trainee Requesting MoonlightingPrivileges
and the Program Director or Chief
Dear Dr. __________________ (Chief) and
Dr. ______________________ (Program Director):
Date: ___________________
I hereby request permission to engage in professional activities
outside the scope of my residency/fellowship training program (i.e.,
"moonlighting"). Specifically, I request permission to
work at the following health care facilities:
(Note: include "home" institution/s, if applicable)
1) ______________________________________
2) ______________________________________
3) ______________________________________
4) ______________________________________
I will limit the hours of moonlighting to a maximum of ___ per month,
and will not allow my "duty hours" (i.e., the sum of time
spent in the training program plus time moonlighting) to exceed
limits set by the program director and by the ACGME
and the ___________ [insert (sub)specialty] RRC. The RRC duty hours
requirements include: _______________ [to be copied from acgme.org/program
requirements]. I recognize that the residency/fellowship
program is my highest professional priority and I will not let additional
professional activities interfere with this. I have read and understand
the Partners Graduate Trainee Moonlighting Policy and will abide
by it.
Sincerely,
___________________________________
(Signed by Graduate Trainee)
Approved by: _________________________ (Chief and/or Program Director)
Date: ________________
As required by the ACGME, the program director must ensure that
a copy of this letter is kept in the trainee's file.
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