Resident Guidelines

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Joined: Tue May 28, 2019 2:38 pm

Wed May 29, 2019 2:04 pm

I am completely stymied on this one. I have reached out to the AAD and they have no further information. Can anyone help? I am working with a Dermatology practice. When talking about residents who are rotating in the practice, how much supervision does she have to provide? A 1st year resident is certainly different than a 3rd year resident. A 3rd year resident should be able to function much more independently but they are still doing procedures and treating patients under the supervising physician's name. It is not a residency clinic so the residents do not fall under the GME Teaching Exemptions. I have shared the Medicare Resident guidelines but the dermatologist feels that these do not apply given the nature of the practice and that rotating in a private clinic like this one is the bulk of their training. I am looking for something concrete I can give to her that is specific to Dermatology residency. Any ideas?
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Mon Jun 03, 2019 9:06 am

Is this a situation where the resident is moonlighting? CMS does have guidance on that scenario and they state if a resident is working outside the facility where the intern or resident has the training program all of these requirements must be met:
● The services are identifiable physician services, the nature of which require performance by a physician in person and contribute to the diagnosis or treatment of the patient’s condition and
● The intern or resident is fully licensed to practice medicine, osteopathy, dentistry, or podiatry by the State where the services are performed
When all of the requirements are met, the services are considered furnished in the intern’s or resident’s capacity as a physician, not in his or her capacity as an intern or resident.
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Joined: Tue May 28, 2019 2:38 pm

Tue Jun 11, 2019 5:31 pm

Thank you. The resident is not moonlighting. This is a training rotation for them in a dermatology clinic.
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Location: Multi-specialty Clinic

Thu Jul 11, 2019 2:01 pm

I, too, am wondering about the same thing. Residents from a local school rotating through physician offices that are not a part of a GME program. This is required time with a physician for credit at school, not moonlighting. No pay is being received. How much can they do or is it a shadowing rotation only? Can the physician use them for any part of the visit? Can they scribe?
Can they be treated as an extender and see patients in that capacity? Would the contract between the physician and the school be enough of a contractual agreement to support Incident-to?
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