ACGME Fellowship & Moonlighting

[stcl]

Can anyone clarify moonlighting restrictions for ACGME-accredited Radiology fellowships? Or specifically point to the documentation from ACGME that describes it? I haven't been able to find anything on their website.

Namely, I've been told that you can't read studies within your specialty for an ACGME fellowship. So if doing Neuro for example, you couldn't read Neuro studies at your institution for extra pay. A) is this even correct? I can't find anything that officially says this.

B) I believe that you could moonlight outside your program, correct? So for example, you do an ACGME Neuro fellowship. Then on a few weekends you moonlight for a private practice reading their studies as a 1099 independent contractor, including Neuro like head CT, CTA head and neck, stroke MR.

c) Do most Neuro programs have either internal non-Neuro moonlighting or allow external moonlighting for their fellows?

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[maxxor]

Can anyone clarify moonlighting restrictions for ACGME-accredited Radiology fellowships? Or specifically point to the documentation from ACGME that describes it? I haven't been able to find anything on their website.

Namely, I've been told that you can't read studies within your specialty for an ACGME fellowship. So if doing Neuro for example, you couldn't read Neuro studies at your institution for extra pay. A) is this even correct? I can't find anything that officially says this.

B) I believe that you could moonlight outside your program, correct? So for example, you do an ACGME Neuro fellowship. Then on a few weekends you moonlight for a private practice reading their studies as a 1099 independent contractor, including Neuro like head CT, CTA head and neck, stroke MR.

c) Do most Neuro programs have either internal non-Neuro moonlighting or allow external moonlighting for their fellows?

My understanding is it has to do with billing.

Residents and Fellows are considered the same for most ACGME rules. You cannot bill as a resident (or fellow) in an ACGME program if the specialty you are billing for is the same as your training one.

In Radiology, we don’t have true separate boards. It’s not like a cardiology fellow moonlighting as a hospitalist. That’s kosher.

Acgme Rad Fellow doing any independent work at their training institution is still doing radiology so they cannot bill.

You can externally moonlight and submit bills to CMS et al, but you cannot do at your training institution.

This was my understanding for why most radiology fellowship programs are not ACGME.

Look for language like “resident professional fee billing policy”

 

[stcl]

Oh it sounds like it's more of a CMS thing than ACGME.

I found this from USC:

Billing for Fellows Participating in Private Practice | USC Office of Culture, Ethics and Compliance

ooc.usc.edu

"Fellows who are not in an ACGME- or ABMS-approved training program are considered “regular” physicians under Medicare billing rules."

 

[maxxor]

Yes. Hence a non-ACGME fellow is an attending in the eyes of billing. It is the ACGME status which prevents you from billing independently and precludes final signing moonlighting.

 

[Gadofosveset]

Maxxor is right. You bill under a trainee status.

ACGME is there for your protection, but to protect you it needs to keep you in a “junior” status.

You can moonlight outside of your program, but you have to report your work hours to your PD and you cannot exceed work hour restrictions.