Definition of Moonlighting
According to the ACGME, Moonlighting is defined as the practice of medicine for financial remuneration that is not recognized as part of the training program by the Program Director. Moonlighting includes trainees being paid for open shifts under supervision from an attending (or “extra shifts for extra pay”).
Moonlighting Process
- Trainees are required to have PD approval to moonlight. Trainees should contact their program for specifics.
- Programs are responsible for:
- Ensuring accurate trainee licensure information in New Innovations
- Uploading PD letter of approval for moonlighting in trainees’ NI file
- Accurate reporting of Moonlighting in Work Hours
Eligibility
- PGY-2 or higher
- In good standing within their program
- BJH-employed trainees may only moonlight internally
- H1B visa holders may be eligible but have to check with their employer
- J-1 visa holders have additional eligibility conditions
- Written approval from program directors and then the program director must submit the completed Intealth form to the appropriate TPL.
- Programs, not individual J-1 physicians, must send the documents to the correct Training Program Liaison:
- WU employed trainees: Jennifer Bondurant
- BJH & SLCH employed trainees: Terra Mouser and Tobit Cosa
- MBMC employed trainees: Margaret Kendrick
Requirements
Trainees must have the following:
- Written Program Director approval (see above box for additional J-1 requirements)
- Permanent state license for where moonlighting will occur:
- For J-1s: must have participated in a US-based ACGME accredited program for three years or more to receive a MO Permanent License
- Personal liability
- A personal BNDD
- A personal DEA license
- MO state license, Social Security number, BNDD required
- Must complete Opioid training (free training available)
- Licensing, BNDD and DEA are the financial responsibility of the trainee and are not reimbursed by the employer
Conditions
- Trainees are not required to moonlight.
- Moonlighting may not interfere with a trainee’s dedicated participation in their training program or their ability to provide quality care to patients.
- Trainees must log all moonlighting hours in New Innovations and those hours are subject to the 80-hour weekly work limit set by ACGME.
- Trainees may not be “on-call” or be assigned Jeopardy while moonlighting.
- Trainees may not moonlight while on leave.
- Moonlighting may only take place outside of scheduled clinical and academic duties.
- The Program Director and the Institution have the right to suspend moonlighting privileges at any time if they feel that a trainee’s primary clinical and/or educational responsibilities within the training program are not being met.
- Additional conditions for J-1 visa holders:
- All activities must take place within the same institution or primary clinical site as the physician’s accredited or non-standard training program and must be educationally appropriate and not extend the training period.
- J-1 physicians are considered to be trainees, not independent providers, regardless of the nature of the program or their level of licensure. They must be under supervision at all times while training in J-1 status and cannot be given final responsibility for diagnosis and treatment of patients.
- J-1 physicians are prohibited from billing for services or functioning in a capacity of an attending/faculty.