I'm pretty sure that the 80 hr work week rules don't apply to fellows. I think that the 80 hr work week rules are being enforced by the agency that accredits residencies, the ACGME or something. Once you finish residency (and are an attending or fellow), there certainly is no federal rule mandating that you work less then 80 hrs a week. A lot of fellows at my school are still working over 80 hrs a week, so if that were a rule, my school would be in violation of that rule; so I'm pretty sure that there is no 80 hr fellow rule.