There are specific requirements that must be met for such "moonlighting" by residents and fellow outside their teaching programs. In order to bill Medicare for the physician services of residents or fellows who are enrolled in a graduate medical education ("GME") program when engaged in "moonlighting."
The criteria for billing moonlighting services are as follows:
1. The services are identifiable physician services;
2. The resident/fellow is fully licensed to practice medicine in the appropriate state(s) and
3. The services can be separately identified from those services that are required as part of the approved GME program.
See 42 CFR 415.208(b)(2). [attached]
Review this rule in its entirety. Also, any resident or fellows hired by your client will need written approval from their residency program to moonlight outside of the GME funded program.
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Thomas W Greeson
Reed Smith LLP
(703) 517-0495
tgreeson@reedsmith.com------------------------------
Original Message:
Sent: 06-30-2023 10:37
From: Keith Carter
Subject: Residents
One of our clients has asked us to explore the use of a Radiology Resident in their Professional Radiology Group. The Resident has one more year in his residency. They specifically want to know if he can be enrolled in Medicare and the group receive reimbursement for his reads. Can anyone direct me to CMS documentation which would assist me in explaining whether this would be possible or not?
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Keith Carter
CEO
Aptus Associates, LLC
Statesboro GA
(912) 764-2455
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