USF GME - Moonlighting Privileges Request July1, 2018 June 30, 2019

Transcription

1 USF GME - Mnlighting Privileges Request July1, 2018 June 30, 2019 Achieving the gals and bjectives f the educatinal prgram must be the highest prfessinal respnsibility f the huse fficer. Mnlighting is nt a right, many prgrams d nt allw mnlighting, and any mnlighting must be vluntary. Trainees requesting permissin t mnlight must be a PGY 2 r higher, and must be in gd standing. By cmpleting this frm, [Print name], [Prgram] attest t the fllwing: I have read and understand the GME plicies and prcedures relating t duty hurs and mnlighting, including the mnlighting plicy, GME-208-A, and the ACGME requirements relating t mnlighting and duty hurs, including hurs free f duty requirements. I have received apprval by bth my Prgram Directr and the Designated Institutin Official PRIOR t beginning any mnlighting activity. * If mnlighting will ccur at an affiliate site, additinal dcumentatin f mnlighting hurs may be required. If nt cmpleted in a timely fashin, mnlighting privileges may be rescinded. I will recrd all mnlighting hurs in New Innvatins, als indicating the training lcatin f the mnlighting. I will adhere t ACGME duty hurs standards, including hurs free f duty requirements, and I understand that bth internal and external mnlighting cunt twards my verall limit f 80 hurs per week averaged ver a fur-week perid. I must request and receive annual apprval t mnlight, and I will reprt all mnlighting sites t bth my prgram and t the Graduate Medical Educatin ffice. I understand that despite receiving annual apprval, my prgram directr r the GME ffice may terminate my right t mnlight at any time. I agree that if I mnlight withut express written apprval r fail t cmply with any GME plicies and prcedures r any ACGME duty hurs standards, I will be subject t disciplinary actin up t and including terminatin frm the prgram. I agree t eliminate mnlighting if it interferes with my training, including educatin and/r patient care. I agree t stp all mnlighting activities if it cntributes t undue fatigue. I understand that this activity is apart frm my assignment and in n way related t my emplyment as a graduate medical student f the University f Suth Flrida. I understand that the University f Suth Flrida is nt respnsible fr and des nt prvide medical prfessinal liability cverage, disability insurance r wrkers' cmpensatin cverage fr nn-prgrammatic prfessinal activity. I agree that the University f Suth Flrida has n bligatin, respnsibility, r liability whatsever fr any injury r harm which I may incur r which may befall me during my perfrmance f r a result f this utside activity. I hereby release, frever discharge, and waive any and all claims I may have nw r in the future arising ut f r cnnected with my utside emplyment activities against the University f Suth Flrida and the State f Flrida, and any all fficers, agents, emplyees, underwriters and insurers, all individually and in their respective fficial capacities. Mnlighting Emplyer: (One lcatin/site per frm) Lcatin: Cntact Persn (Name/Phne/ ): Full Medical License Number: Expiratin Date: Signature f Trainee: Date: I certify that this trainee is in gd standing. I will mnitr this trainee t ensure mnlighting des nt negatively impact his/her medical educatin and training. Signature f Prgram Directr: Affiliate Hspital Acknwledgement (if applicable) Signature f DIO: Date: Date: Date (Once Trainee and PD have signed, Return signed frm t Patti Taylr, GME via ptaylr@health.usf.edu r Fax at ) PLEASE ALLOW 2-4 WEEKS FOR REVIEW/APPROVAL PROCESSING AFTER AFFILIATE ACKNOWLEDGEMENT

2 Resident Name Current Prgram Current PGY Medicare Resident Mnlighting Rules: Decisin Tree The fllwing guide allws a hspital t cmplete a step-by-step analysis t determine the prper Medicare payment categry fr individual trainees wh are engaged in patient care activities bth within the scpe f and apart frm their residency training prgrams. Thrughut this dcument, the term "resident" is used t describe an intern, resident, r fellw (cnsistent with the Medicare definitin f the term). Prgram Apprval Step 1: Is resident participating in an "apprved" prgram? YES, if the prgram is accredited by ACGME/AOA r has ABMS-apprved specialty r subspecialty certificatin (see list here). G t Step 2. N, if nt ACGME/AOA accredited r ABMS-apprved certificatin. G t Step 3. Nte: Determinatin f whether resident is in an apprved prgram is made at the time f the training and cannt be applied retractively, even if an unapprved prgram is apprved during a later cst reprting perid. Reimbursement Issues Step 2: (Apprved Prgrams) 2A. Is the resident engaged in activities that fall within the scpe f the residency training prgram? Resident time must be cunted fr direct graduate medical educatin (DGME) and indirect medical educatin (IME) payment purpses. Resident may nt bill under wn name fr services prvided. Including time in FTE cunt fr hspital cst reprting purpses is nt ptinal (even if hspital is training in excess f Medicare DGME and IME caps). 2A(i): Is the resident being supervised accrding t requirements at 42 C.F.R (requiring teaching physician's presence during key r critical prtin f the service r prcedure) r under the primary care exceptin requirements at 42 C.F.R ? Yes. Only supervising physician may submit prfessinal bill fr payment under the physician fee schedule. NO. G t Step 2B. N. N prfessinal bill may be submitted. Hspital shuld cnduct fact-specific beneficiary inducement analysis, given that free services are ptentially being prvided t Medicare beneficiaries. 2B. Presuming the resident is engaged in activities that fall utside the scpe f the residency training prgram, are the activities taking place in an inpatient setting (including an inpatient subprvider)? 2B(i): Are the inpatient activities taking place in a hspital where the resident als engages in training as part f her/his residency prgram? Yes. Resident may nt bill under the physician fee schedule in her/his wn name (i.e. "mnlighting" is nt permitted). Hspital shuld cnduct fact-specific beneficiary inducement analysis, if free services are ptentially being prvided t Medicare beneficiaries.

3 NO. G t Step 2C. N. "Mnlighting" is permitted in the inpatient setting f a hspital where the resident is nt engaged in training. Prfessinal bill may be submitted in resident's name, if the fllwing tw requirements are met: (1) Services are identifiable physician services, the nature f which require perfrmance by a physician in persn and cntribute t the diagnsis r treatment f the patient's cnditin; and (2) The resident is fully licensed t practice medicine, stepathy, dentistry, r pdiatry by the State in which the services are perfrmed. Nte: time spent "mnlighting" des indeed cunt tward duty hur requirements. 2C. Presuming the resident is engaged in activities that fall utside the scpe f the residency training prgram, are the activities taking place in a prvider-based utpatient r emergency department setting? 2C(i): Is the utpatient r emergency department where the resident is training prviderbased t a hspital where the resident als engages in training as part f her/his residency prgram? Yes. 2C(i)(A): Are all 3 f the fllwing requirements met? (1) Services are identifiable physician services, the nature f which require perfrmance by a physician in persn and cntribute t the diagnsis r treatment f the patient's cnditin; (2) The resident is fully licensed t practice medicine, stepathy, dentistry, r pdiatry by the State in which the services are perfrmed; and (3) The services can be separately identified frm thse services that are required as part f the training prgram. Yes. "Mnlighting" is permitted, and prfessinal bill may be submitted in resident's name. Hspital shuld dcument why activity is cnsidered "separately identifiable" frm residency training. N. "Mnlighting" is nt permitted, and prfessinal bill may nt be submitted in resident's name. Hspital shuld cnduct fact-specific beneficiary inducement analysis, given that free services are ptentially being prvided t Medicare beneficiaries. Nte, hwever, that if services cannt be separately identified frm thse required as part f the training prgram, CMS will assume that services are within the scpe f the training prgram and time must be included in DGME/IME DGME/IME FTE cunt. N. 2C(ii): Is the utpatient r emergency department where the resident is training prvider-based t a hspital where the resident des nt engage in training as part f her/his residency prgram?

4 Yes. "Mnlighting" is permitted in the utpatient r emergency department f a hspital where the resident is nt engaged in training. Prfessinal bill may be submitted in resident's name, if the fllwing tw requirements are met: Services are identifiable physician services, the nature f which require perfrmance by a physician in persn and cntribute t the diagnsis r treatment f the patient's cnditin; and The resident is fully licensed t practice medicine, stepathy, dentistry, r pdiatry by the State in which the services are perfrmed. N. G t Step 2D. N. [End f analysis; please prvide examples f ther scenaris if further analysis is desired.] 2D. Presuming the resident is engaged in activities that fall utside the scpe f the residency training prgram, are the activities taking place in a clinical care setting that is NOT prvider-based t any hspital? "Mnlighting" is permitted, and prfessinal bill may be submitted in resident's name, if the fllwing tw requirements are met: (1) Services are identifiable physician services, the nature f which require perfrmance by a physician in persn and cntribute t the diagnsis r treatment f the patient's cnditin; and (2) The resident is fully licensed t practice medicine, stepathy, dentistry, r pdiatry by the State in which the services are perfrmed. NO. [End f analysis; please prvide example f ther setting if further analysis is desired.] Step 3: (Unapprved Prgrams) 3A. Is resident fully licensed in the State where the resident is training? Prfessinal bill may be submitted in resident's name. NO. Prfessinal bill may nt be submitted in resident's name. Hspital shuld cnduct fact-specific beneficiary inducement analysis, given that free services are ptentially being prvided t Medicare beneficiaries. Cntinue t 3A(i). 3A(i): Is the resident enrlled and participating in a frmally rganized, standardized, structured curse f study that lasts at least ne year in duratin? Yes. Hspital may receive Medicare Part B reasnable cst payment (under 42 C.F.R ) by reprting csts fr resident n Medicare Hspital Cst Reprt Frm CMS , WS A, line 100 and WS B, line 100, and cmpleting Wrksheet D-2 Part I. Hspital will receive Part B payment calculated as fllws: (reasnable csts f services minus beneficiary deductible) X 80% f the remaining amunt. What are the "reasnable csts f services"? Resident salaries and fringe benefits? YES. Faculty cmpensatin csts? NO. Other direct and indirect prgram expenses? NO. Applies equally t services furnished t hspital inpatients and utpatients. Payment made n biweekly basis with true up n settled cst reprt (like DGME payments). Ntes: If residency has been nging and csts were nt previusly incurred by the hspital, seek advice f cunsel abut implicatins f cmmunity

5 supprt / redistributin f cst rules befre claiming residents n "unapprved prgrams" line f cst reprt. CMS stated (in 2010) that the agency was cnsidering eliminating this payment ptin fr any individual wh has already cmpleted ne residency prgram, regardless f licensure status. CMS has nt yet mved in this directin, thugh. N. Hspital may nt receive Medicare Part B reasnable cst payment by cmpleting Wrksheet D-2 Part I. N ther Medicare reimbursement ptins remain. Cmpleted by (print name) Cmpleted by (signature) Cmpleted by date: Apprved by Cuc Mai, M.D., Sr. Assciate Dean, GME, and DIO Apprved by (signature) Apprved by date: Anytime a red bx is checked, the frm cmpletin is at a stpping pint. N further wrk needed. Anytime a green bx is checked, cntinue t next step as indicated. RELEVANT CITATIONS CMS Regulatins 42 CFR : Cnditins fr payment n a fee schedule basis fr physician services in a teaching setting. 42 CFR : Physician fee schedule payment fr services f teaching physicians. 42 CFR : Exceptin: Evaluatin and management services furnished in certain centers. 42 CFR : Services f residents nt in apprved GME prgrams. 42 CFR : Services f mnlighting residents. Federal Register Preamble Discussins 54 Fed. Reg , (Sept. 29, 1989), "Identifying Apprved Teaching Prgrams". 60 Fed. Reg , (Dec. 8, 1995), "Public Cmments n the Teaching Physician Prpsal in the Prpsed Rule and Our Respnses". 75 Fed. Reg , (Aug. 16, 2010), "Frmal Enrllment and Participatin in a Prgram". Medicare Manual Prvisins Medicare Claims Prcessing Manual, Chapter 12, 100, Teaching Physician Services Medicare Claims Prcessing Manual, Chapter 4, Biweekly Interim Payments fr Certain Hspital Outpatient Items and Services that are Paid n a Cst Basis, and Direct Medical Educatin Payments, Nt Included in the Hspital Outpatient Prspective Payment System Prvider Reimbursement Manual, Part 2, Prvider Cst Reprting Frms and Instructins, Chapter 40, frm CMS