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University of California San Francisco

Training Program

Foreground Victoria Cheung

Moonlighting Policy

It is the responsibility of each resident and fellow to ensure that he/she is in compliance with his/her program’s policy.

There is no “internal moonlighting” within Radiation Oncology at UCSF.

External moonlighting is defined as work for pay performed at a non-UCSF site or a site that does not participate in the resident or clinical fellow’s training program. External moonlighting hours must be documented and must comply with the written policies of the ACGME, UCSF GME, and the program regarding clinical and educational work hours.

Moonlighting IS NOT REQUIRED. Moonlighting IS ALLOWED, but ONLY if the below criteria are met:

Visa (i.e. OPT, H1B, J1) holders may not moonlight.

Because residency education is a full-time endeavor, residents must ensure that moonlighting does not interfere with their ability to achieve the goals and objectives of their educational program, and must not interfere with the resident’s fitness for work nor compromise patient safety.

Residents are responsible for ensuring that moonlighting and other outside activity does not result in fatigue that might affect patient care or learning.

Hours spent moonlighting count toward the 80-hour maximum weekly work hours and will be closely monitored by the program in a manner similar to other duty. Residents are responsible for complying with ALL aspects of the Clinical and Educational Work Hours Policy:

  • Resident work hours must be limited to no more than 80 hours per week, averaged over a four-week period, inclusive of all in-house clinical and educational activities, time spent on at-home call, clinical work done from home, and all moonlighting. Of note, as of July 1, 2017, time spent by residents on at-home call and at-home patient care activities such as contouring target volumes and normal tissue volumes and working on notes for the electronic medical record also counts towards the 80-hour maximum weekly limit, averaged over a four-week period.
  • Residents should have eight hours off between scheduled in-house clinical work and education periods. Residents must be scheduled for a minimum of one day in seven free of clinical work, home-call, and required education (when averaged over four weeks). These free days cannot include at-home call. Independent studying does not count toward work hours.
  • Residents and fellows must have at least 14 hours free of clinical work and education after 24 hours of in-house call.
  • Clinical and educational work periods for residents and fellows must not exceed 24 hours of continuous scheduled clinical assignments. Up to four hours of additional time may be used for activities related to patient safety, such as providing effective transitions of care, and/or trainee education.
  • In rare circumstances, after handing off all other responsibilities, a resident or fellow,on his/her own initiative, may elect to remain or return to the clinical site in the following circumstances: to continue to provide care to a single severely ill or unstable patient; humanistic attention to the needs of a patient or family; or to attend unique educational events. These additional hours of care or education will be counted toward the 80-hour weekly limit.
  • Night float must occur within the context of the 80-hour and one-day-off-in-seven requirements. The maximum number of consecutive weeks of night float, and maximum number of months of night float per year may be further specified by each ACGME Review Committee.
  • Residents and fellows must be scheduled for in-house call no more frequently than every third night (when averaged over a four-week period).
  • Time spent on patient care activities by residents and fellows on at-home call must count toward the 80-hour maximum weekly limit. The frequency of at-home call is not subject to the every-third-night limitation, but must satisfy the requirement for one day in seven free of clinical work and education, when averaged over four weeks. At-home call must not be so frequent or taxing as to preclude rest or reasonable personal time for each resident. Residents and fellows are permitted to return to the hospital while on at-home call to provide direct care for new or established patients. These hours of inpatient patient care must be included in the 80-hour maximum weekly limit.
  • An ACGME Review Committee may grant rotation-specific exceptions for up to 10 percent or a maximum of 88 clinical and educational work hours to individual programs based on a sound educational rationale. In preparing a request for an exception, the Program Director must follow the clinical and educational work hour exception policy from the ACGME Manual of Policies and Procedures. Prior to submitting the request to the Review Committee, the Program Director must obtain approval from the GMEC and DIO.

Written PRE-APPROVAL of the moonlighting activity by the Program Director IS REQUIRED. It is the resident’s responsibility to complete the attached form and obtain written permission to moonlight from the Program Director prior to beginning the moonlighting activity.

External moonlighting hours must be documented (including days, hours, location, and brief description of type of service(s) provided) in order to comply with Medicare reimbursement requirements for GME. The attached “Moonlighting Documentation Form” is to be used for this purpose.

The Program Director will monitor trainee performance in the program to ensure that moonlighting activities are not adversely affecting patient care, learning, or trainee fatigue. The Program Director may enlist the assistance of the Chief Resident and/or the Attending Physician(s) with whom the resident is working to help with this monitoring. If the Program Director determines that the resident’s performance does not meet expectations, permission to moonlight will be withdrawn. Any residents moonlighting without written pre-approval will be subject to disciplinary action.

The Program Director will also monitor compliance with the Clinical and Educational Work Hours Policy. If moonlighting is interfering with work hours involved in the training program, permission to moonlight will be withdrawn.

Moonlighting activity (if any) and policy will be reviewed at least yearly at Radiation Oncology Departmental Education Committee Meetings. Any adverse effects will be discussed.

EXTREMELY IMPORTANT:

For external moonlighting, the trainee is not covered under UC’s professional liability insurance program as the activity is outside the scope of university employment. The trainee is responsible for ensuring liability coverage from another source, obtaining their own Radiology X-Ray Supervisor and Operator certificate, DEA licensure, Medicare (or other governmental) provider number and billing training, and licensure requirements by the California Medical Board as well as any other requirements for clinical privileging at the employment site.

UCSF Radiation Oncology Moonlighting Policy and Approval Form for Residents:

Redefining Possible