Resident Guidelines

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

Moderators: NAMAS Moderator, Shannon DeConda

Post Reply
User avatar
Site Admin
Posts: 501
Joined: Mon Apr 09, 2012 1:54 pm

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.
Posts: 91
Joined: Fri Jun 23, 2017 1:41 pm
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?
Post Reply