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Moonlighting

Credentialing Resource Center Connection, June 26, 2008

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Sally J. Pelletier, CPMSM, CPCS, is a consultant with The Greeley Company, a division of HCPro, Inc., specializing in the areas of credentialing and privileging.

Dear credentialing colleague:

Frequently hospitals utilize moonlighters or “house staff” to provide coverage for the emergency department or the hospital (“house”) on nights and weekends. Residents, fellows, or other staff members may serve as moonlighters depending on hospital policy and state licensing laws. The Accreditation Council for Graduate Medical Education (ACGME) defines resident and fellow moonlighters as follows: “Patient care activities external to the educational program that residents/fellows engage in at sites used by the educational program (internal moonlighting) and other healthcare sites.”

These practitioners are typically residents in their last year or fellows. Often these moonlighters are a source of confusion for medical staff leaders, credentialing specialists, and hospitals who are wondering:

• Do these practitioners need to be credentialed?
• Do these practitioners need to be privileged?
• Do our bylaws allow for physicians who have not completed a residency program to qualify for privileges?

It is best practice for institutions who are considering utilizing moonlighters to provide coverage and patient care in their facilities to:

• Evaluate their internal documents (e.g., medical staff bylaws and privileging criteria) to make sure that they do not require completion of residency training for granting of privileges. 
• Check out the specific moonlighting policy of the practitioner’s post-graduate training program to make sure that it allows moonlighting. There is information related to the ACGME’s position on moonlighting available on its Web site at www.acgme.org. 
• Make sure that the residents have a full unrestricted license to practice independently in their state.
• Fully credential these physicians in accordance with existing credentialing policies.
• Recognize that FPPE and OPPE apply if your organization is a Joint Commission-accredited facility.

Some organizations will have a “house staff” category with qualifications that allow for practitioners to be eligible for appointment and privileges upon completion of medical school, not residency.  It is important to note that the creation of this type of new category is not necessary. Moonlighters do not need medical staff membership; they do need clinical privileges in order to provide independent patient care or treatment.

Once your organization has carefully discussed the benefits and risks of utilizing moonlighters and decided to move forward, instead of creating a new staff category it may wish to consider adding a simple statement to your medical staff bylaws. This statement could waive the completion of residency requirement for moonlighting or house staff physicians. In addition, it is important to make sure that the criteria on the applicable privilege form(s) allow for someone who has not completed residency training to practice independently.

Remember, credentialing has no other master than the patient.

That’s all for this week.

All the best,

Sally J. Pelletier, CPMSM, CPCS
http://www.greeley.com/consulting.cfm

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