University of California San Francisco

Program Moonlighting Policy

I. PURPOSE

This document (updated December 2024) outlines the program moonlighting policy of the UCSF General Surgery Residency Program

II. BACKGROUND

The moonlighting system at UCSF was implemented to decompress work for clinical residents and ensure adherence to ACGME duty hour regulations. The moonlighting workforce consists of general surgery, vascular, plastic surgery, neurosurgery, and urology residents who are in their research years, as well as a number of other physicians outside of the residency program, with various backgrounds, all of whom have completed at least one year of surgical residency training. 

Prior to AY21-22, the departmental policy for moonlighting has restricted the moonlighting activities of clinical residents to only during vacation. Due to increased demand for moonlighters and a smaller workforce that can take shifts, interest has grown to allow clinical residents to moonlight. 

This document serves to delineate policies for moonlighting for both clinical and research residents in the department of surgery

III. DEFINITIONS

  • Internal moonlighting is defined as extra work for extra pay performed at a site that participates in the residents’ training program.
  • External moonlighting is defined as work for pay performed at a site that does not participate in the residents’ training program.
  • “Clinical residents” are general surgery residents who are in their clinical years of general surgery residency. These residents are active on the ACGME roster and are subject to the requirements and regulations governing all ACGME-accredited training programs. 
  • “Research residents” are surgical residents who are in their dedicated research time and are designated as inactive on the ACGME roster. 

IV. PRINCIPLES

  • All moonlighting is voluntary.
  • The moonlighting system was originally implemented to allow research residents to decompress the work of clinical residents and to improve compliance with the ACGME duty hour regulations. Moonlighting by clinical residents should not compromise their ability to comply with these duty hour regulations
  • Moonlighting by clinical residents cannot interfere with the patient care obligations or educational activities of the clinical resident’s assigned service. 
  • Each rotation must have clear expectations for service obligations, weekend coverage, and overnight call that is expected for all residents on the service. These obligations must comply with ACGME duty hour regulations. Clinical duties within the scope of the expectations of the rotation are not eligible for compensation as a moonlighter. 
  • Clinical residents are not allowed to participate in external moonlighting
  • External and internal moonlighting is allowed for research residents
  • All moonlighting is prohibited during designated family or medical leave periods, per UCSF HR policy. This does not include time designated as vacation.

V. POLICIES

  • Internal Moonlighting (all):
    • Internal moonlighting must be supervised by faculty and is not to exceed the level of clinical activity currently approved for the trainee.
    • All moonlighters (clinical residents, research residents, and other physicians) must be approved by one of the moonlighting faculty leads (Dr. K. Hirose and C. Gomez-Sanchez), after appropriate evaluation and/or interview as needed. 
    • Moonlighters will be approved for specific services as deemed appropriate by the moonlighting faculty leads
    • Performance concerns by any moonlighter should be forwarded to the moonlighting faculty leads for further action
    • Moonlighters at the SFVAMC and at Kaiser are subject to those respective institutions’ credentialing processes and policies.
  • Internal moonlighting for Clinical Residents
    • Clinical residents who wish to moonlight during clinical time must have the written approval of the service education lead of their current rotation, in addition to the program director.  Each moonlighting shift must be approved.
    • Clinical residents’ moonlighting shifts must not interfere with the patient care and educational obligations to their assigned clinical service. 
    • Clinical residents who wish to moonlight during vacation must have the written approval of the program director. This approval will apply for the duration of the vacation block. Duty hours must be recorded for these shifts and must comply with ACGME regulations.
    • Clinical residents must record duty hours in Medhub and when combined with the normal work hours, must be below 72 hours for the week and ensure one day off per week (Sun-Sat)
    • Clinical residents may moonlight on the service they are currently assigned to with approval of the service education lead and program director, and only at a level below their current training level, for example the KTU R3 may moonlight as the KTU R1, but the Trauma R4 may not moonlight as the Trauma R4. 
    • These policies are subject to change in the event of 1) increases in duty hour violations 2) ACGME survey results showing a high rate of non-compliance with duty hour rules 3) ACGME citation for duty hours
    • These policies apply only to moonlighting shifts at UCSF sites and SFGH. 
  • External Moonlighting: External moonlighting is allowed only during residents’ dedicated research time. This activity is not covered under the University’s professional liability insurance program as this activity is outside the scope of University employment. The trainee will be responsible for his/her own professional liability coverage and any requirements for clinical privileging at the employment site.
  • Eligibility
    • Trainees on H1B or J1 visas are not allowed to moonlight.
    • PGY1 trainees are not allowed to moonlight
    • Trainees must have a full California medical license in order to moonlight
    • No clinical residents assigned to rotations at the SFVAMC may moonlight

VI. PROCEDURES

1. A trainee must have written pre-approval from the Program Director if he/she wishes to moonlight. Trainees must use the internal and/or external moonlighting form depending upon the type of moonlighting he/she wishes to do.

2. A clinical trainee who is moonlighting must track and record those days and hours in MedHub work hour tracking system regardless if the moonlighting is internal or external.

3. If excessive fatigue or performance issues are noted by the trainee’s supervisors and confirmed by the Program Director and moonlighting is felt to be a contributing factor to the fatigue, permission for moonlighting will be withdrawn.

4. Violations of the Moonlighting Policy may lead to Departmental disciplinary action.

VII. SCOPE

The Department of Surgery policy applies to all department residents during their rotations at any of the teaching sites (UCSF Health (Parnassus, Mission Bay, Mt. Zion), Zuckerberg San Francisco General Hospital, San Francisco Veterans Affairs Medical Center, Kaiser Hospital, and California Pacific Medical Center).

Addendum

Specific scenarios

  • Unexpected absences

In the setting of a categorical/preliminary GS resident, plastics resident, vascular 0/5 resident not being available to work on general surgery service due to unexpected absence, e.g. fatigue, illness, family emergency, etc, the jeopardy resident will be available to fill in for this absence. 

In the setting of an advanced practice provider not being available to work due to an unexpected absence, the service must make arrangements to accommodate this deficiency. The shift may be offered as a moonlighting shift, but if unfilled, the jeopardy resident will not be used to fill this deficiency

  • Expected absences

Planned resident absences beyond the usual allotment of days off for the rotation must be approved by the administrative chief residents and program director. These days off must be requested in advance in order for the call schedule to be planned. 

Expected staffing deficiencies due to advanced practice providers (e.g. vacation, parental leave, unfilled positions, etc), will be offered up as moonlighting shifts but cannot be guaranteed to be filled beyond the allotment for that service per month. Other deficiencies must be made up by modification of schedules by the providers on the service. 

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