ED Coding and Reimbursement Alert

Reader Question:

Can I Bill For a Moonlighting Resident's Services?

Question: I have residents who moonlight for us in the emergency department. I also have APRN’s. Can the residents sign off on the APRNs charts?

Kentucky Subscriber

Answer: In general, CMS’ rules state that residents can’t supervise Advanced Practice Providers, but that would vary state to state and by hospital by-laws.  Theoretically, if a resident has a full medical license and is moonlighting as a fully credentialed and licensed physician and the hospital allows them to do so, then yes, a moonlighting resident could supervise an APP. 

The American College of Emergency Physicians, (ACEP) has a policy against residents supervising APRNs based on a similar statement from the American Board of Emergency Medicine (ABEM).

Providers of Unsupervised Emergency Department Care The American College of Emergency Physicians (ACEP) endorses the 2000 position statement of the Society for Academic Emergency Medicine (SAEM) on the “Qualifications for Unsupervised Emergency Department Care,” and believes that the independent practice of emergency medicine is best performed by specialists who have completed American Board of Emergency Medicine (ABEM) or American Osteopathic Board of Emergency Medicine (AOBEM) certification, or have successfully “completed an Accreditation Council for Graduate Medical Education (ACGME) or American Osteopathic Association (AOA) accredited emergency medicine residency, and is in the process of completing ABEM or AOBEM examinations.”

“Residents-in-training or other physicians who do not meet these criteria are less likely to possess the cognitive and technical skill set necessary for rendering unsupervised care for the tremendous breadth and acuity of situations encountered in an ED.”

ACEP believes that advanced practice registered nurses or physician assistants should not provide unsupervised emergency department care. 

ACEP believes that “unsupervised ED practice is best provided by fully trained emergency medicine specialists.”