Policies / Moonlighting and Outside Work Policy

Date Established: 02/08/2007

Revision History: 7/22/09, 8/8/13, 10/09/14, 6/6/17, 7/12/18; 6/10/21, 5/12/22, 10/10/24, 12/11/25

Policy Reviewers: Policy Subcommittee, UW Graduate Medical Education Committee (GMEC)

All UW residents and fellows that are in programs accredited by the Accreditation Council for Graduate Medical Education (ACGME) and Commission on Dental Accreditation (CODA) sponsored by the UW School of Medicine (UWSOM).

This policy also applies to fellows appointed as Fellow Non-ACGME, Fellow Non-ACGME Stipend who are participating in non-ACGME accredited training programs, and Maternal Fetal Medicine fellows holding an Acting Instructor title.

This policy applies to Clinician Researchers and Non-ACGME Chief Residents in a limited capacity as outlined below.

All residents and fellows to whom this policy applies are hereafter referred to as “Residents”.

Outside Work is defined as any voluntary, clinical or non-clinical work that is outside of a trainee’s regularly scheduled program duties. This includes Internal and External Moonlighting, Extra Pay for Extra Duty and Additional Non-Clinical Work. Outside work requires pre- approval by the resident’s Program Director and GME Office.

3. Policy

Work Outside of the Training Program (“Outside Work”) is defined as any voluntary, clinical, or non-clinical work that is outside of a resident’s regularly scheduled program duties, done for additional compensation. Outside work includes (1) Internal Moonlighting, (2) External Moonlighting, (3) Extra Pay for Extra Duty (EPED) and (4) Additional Non-Clinical Work.

Outside Work does not include medical volunteering, which is governed by the UW GME Medical Volunteer Activities Policy.

Several policies and laws govern Outside Work, including but not limited to the Accreditation Council for Graduate Medical Education (ACGME) Institutional Requirements and Common Program Requirements, the Washington State Ethics in Public Service Act, and University of Washington Executive Order No. 57 (“Outside Professional Work Policy). The GME Office is designated by the UW School of Medicine as the unit with permission to review and approve such requests for residents.

The use of the term “moonlighting” in this policy is for internal purposes and is not intended to match the definition of “moonlighting” in CMS regulations. The outside work types mentioned below are specific to UW GME.

Regardless of whether they are participating in an ACGME-accredited program, residents who choose to engage in Outside Work activities must ensure that the activities do not interfere with their ability to achieve the goals and objectives of their training program.

For purposes of this policy, UW Medicine Sites include: UW Medical Center-Montlake, UW Medical Center-Northwest, Harborview Medical Center, UW Medicine Primary Care, and Airlift Northwest.

• Fred Hutch Cancer Center and Valley Medical Center are handled on a case-by-case basis.
• Seattle Children’s Hospital and VA Puget Sound Healthcare System are considered external sites, unless an opportunity is otherwise approved by UW GME as EPED.

The UWSOM permits residents from all departments to engage in Outside Work if they are eligible, and that such activities do not interfere with the responsibilities, duties or assignments of their stipend-supported research, if applicable. Approval is also contingent on Outside Work activities complying with all UW policies and Washington State law.

A resident who wants to participate in any type of Outside Work must complete the GME Moonlighting Request Form located on the Moonlighting and Outside Work webpage.

Eligibility requirements are covered under Article 18 of the RFPU-NW Collective Bargaining Agreement which includes provisions regarding Outside Work for residents who are part of the collective bargaining unit as outlined in the RFPU-NW Bargaining Unit Summary.

Approval of any Outside Work activities is valid for the current academic year only. The resident must submit a new request to the GME office to participate in such activities each academic year (generally July 1 – June 30).

Any resident found to be misrepresenting or underreporting Outside Work activities may be restricted from participating in these activities.

A. ACGME Requirements

• CPR 6.20. Maximum Hours of Clinical and Educational Work per Week: Clinical and educational work hours must be limited to no more than 80 hours per week, averaged over a four-week period, inclusive of all in-house clinical and educational activities, clinical work done from home, and all moonlighting. (Core)
• CPR 6.25.a. Moonlighting
  • 6.25.a) Moonlighting must not interfere with the ability of the resident to achieve the goals and objectives of the educational program and must not interfere with the resident’s fitness for work nor compromise patient safety. (Core)
  • 6.25.a) Time spent by residents in internal and external moonlighting (as defined in the ACGME Glossary of Terms) must be counted toward the 80-hour maximum weekly limit. (Core)
  • 6.25.b) PGY-1 residents are not permitted to moonlight. (Core)
• IR. 4.11. Clinical and Educational Work Hours: The Sponsoring Institution must maintain a clinical and educational work hour policy that ensures effective oversight of institutional and program-level compliance with ACGME clinical and educational work hour requirements. (Core)
  • IR 4.11.a Moonlighting: The Sponsoring Institution must maintain a policy on moonlighting that includes the following:
    • 4.11.a.1) residents/fellows must not be required to engage in moonlighting; (Core)
    • 4.11.a.2) residents/fellows must have written permission from their program director to moonlight; (Core)
    • 4.11.a.3) an ACGME-accredited program will monitor the effect of moonlighting activities on a resident’s/fellow’s performance in the program, including that adverse effects may lead to withdrawal of permission to moonlight; and, (Core)
    • 4.11.a.4) the Sponsoring Institution or individual ACGME-accredited programs may prohibit moonlighting by residents/fellows. (Core)

B. Additional Requirements by Appointment Type

1. Residents who hold Resident/Fellow ACGME Stipend or Fellow Non-ACGME Stipend titles who seek to perform work outside of their UW appointment must also complete the Request to Perform Additional Work form found on the School of Medicine Resource Portal. This should be submitted to their department, not the GME office, to keep on file.
   • Activities related to research projects by Fellow Non-ACGME Stipend must be approved in writing by the Program Director and the Office of Research and Graduate Education (RGE) prior to engaging in such activities.
   • Such activities may not interfere or overlap with the NRSA-supported experience.
2. Clinician Researchers and Non-ACGME Chief Residents must submit the GME Moonlighting Request Form to participate in any external outside work requests.
   • Internal moonlighting requests are to be managed by the applicable department and do not require a GME request form to be submitted.
   • This is the only provision in this policy that applies to these appointment types.
3. Residents under visa sponsorship are permitted to engage in additional work and clinical activities in limited circumstances. These are addressed in the GME Visa Policy.
4. Residents in the Department of Pediatrics and/or at Seattle Children’s Hospital (SCH)-based programs must also obtain advance approval by the SCH GME Office.

C. Moonlighting & Outside Work Types

Outside Work Activities

Outside Work Activity	Non/Clinical	Scope of Training	Site
External Moonlighting	Clinical	Outside scope of training	Non-UW Medicine site
Internal Moonlighting	Clinical	Outside scope of current training program	UW Medicine site
Extra Pay for Extra Duty	Clinical	Within scope of current training program	Current program training site, funded by UW
Additional Non-Clinical Work	Non-clinical	Outside scope of training	Varies: Internal or External

1. External Moonlighting

1. Scope of Practice: Voluntary, compensated, medically related work performed outside the institution where the resident is in training or at any of its related participating sites. ACGME Glossary. External Moonlighting is extracurricular medical practice that is outside the scope of the Accredited Training Program, performed at a non-UW Medicine Site.
2. Liability Coverage: University of Washington professional liability coverage does not apply to external moonlighting activities.
   • Residents who engage in External Moonlighting activities must obtain confirmation of coverage by the site’s malpractice insurance or obtain their own private malpractice insurance.
3. Medical Licensure: Residents engaging in External Moonlighting activities must meet the licensure requirements of the state in which the moonlighting activities will occur.
   • Residents are required to hold a full medical license (MD) in Washington State when moonlighting.
     • Under Washington State Law (RCW 18.71.095(3)), a limited license “. . . shall permit the resident physician to practice medicine only in conjunction with his or her duties as a resident/fellow physician and shall not authorize the physician to engage in any other form of practice.”
   • Approval of External Moonlighting activities by the UW does not constitute the University’s endorsement that the resident has the appropriate license. It is the resident’s responsibility to ensure that they have appropriate licensure before engaging in any moonlighting activities.
4. DEA Registration: Residents who engage in External Moonlighting must obtain an individual DEA registration if prescribing during this activity.
   • Fee-exempt DEA registrations obtained through the UWSOM are restricted to activities performed by residents within the scope of their training program, Internal Moonlighting or Extra Pay for Extra Duty.
   • A fee-exempt registration may also be obtained for work at federal state or local government-operated hospitals and institutions.

2. Internal Moonlighting

1. Scope of Practice: Voluntary, compensated, medically related work (not related to training requirements) performed within the institution in which the resident is in training or at any of its related participating sites. ACGME Glossary. Within UW Medicine, Internal Moonlighting is extra clinical work that is outside the scope of the current Training Program, performed for additional compensation at a UW Medicine
2. Liability Coverage: University of Washington professional liability coverage will extend to most internal moonlighting opportunities but will be determined on a case-by-case basis and will be communicated during approval by the GME office.
3. Medical Licensure: Residents are required to hold a full medical license in Washington State when moonlighting.
   • Under Washington State Law (RCW 18.71.095(3)), a limited license “. . . shall permit the resident physician to practice medicine only in conjunction with his or her duties as a resident/fellow physician and shall not authorize the physician to engage in any other form of practice.”
   • Approval of Internal Moonlighting activities by the UW does not constitute the University’s endorsement that the resident has the appropriate license.
   • It is the resident’s responsibility to ensure that s/he is appropriately licensed before engaging in any moonlighting activities.
4. Endorsement by the Department Chair and approval by the GME Office of the Internal Moonlighting activity itself must be on file in the GME Office. Departments should request approval for new Internal Moonlighting activities by completing the GME Internal Moonlighting & Extra Pay for Extra Duty (EPED) Activity Request.
5. Professional Fee Billing: Billing by any resident withing UW Medicine is generally prohibited.

3. Extra Pay for Extra Duty (EPED)

1. Scope of Practice: Extra clinical duties that occur within the scope of the resident’s current training program, performed outside their regularly scheduled duties, or required responsibilities, assumed by the resident on a voluntary basis, and which are performed for additional compensation at a program training site and funded by the department.
2. Liability Coverage: University of Washington professional liability coverage will be extended for EPED opportunities but will be determined by GME on a case-by-case basis.
3. Medical Licensure: Residents are required to hold, at minimum, a limited license for all EPED opportunities. A full license may not be required but will be determined by the GME office on a case by case basis.
4. The GME office must give final approval before any activity can be categorized as EPED.
5. Endorsement by the Program Director or designee and approval by the GME Office of the EPED activity must be on file in the GME Office. Programs should request approval for new internal activities by completing the Internal Moonlighting & Extra Pay for Extra Duty (EPED) Activity Request.

4. Additional Non-Clinical Work

1. Scope of Practice: Additional non-clinical work outside of the approved training program’s scope, whether internal or external to UW Medicine sites.
2. Liability Coverage: University of Washington professional liability coverage will be determined by GME on a case-by-case basis.
3. Medical Licensure: It is the resident’s responsibility to ensure any required medical licensure requirements are met.
4. Additional Approval Required for External Requests: The Outside Professional Work Policy, UW Executive Order 57, establishes the procedures through which academic personnel may be approved to engage in professional activities for compensation (such as consulting) outside of their University duties. Information accessible through the Outside Professional Work for Compensation webpage provides details of the relevant policies and procedures.
   • All external, non-clinical work requests require a 1460 form to be completed.

D. Information on entering compensation for Outside Work activities into Workday

Programs and departments can find information about entering compensation for activities within UW Medicine (Internal Moonlighting, Extra Pay for Extra Duty and some additional non-clinical work) on the Employee Workday One-Time Payment Reasons webpage.