Residency Program Closure or Interruption Secondary to Disaster
DEPT: MEDICAL EDUCATION
POLICY #: 8240.14
To define the process and procedure for graduate medical education programs in the event of disruption by emergencies, catastrophic events, or natural disasters.
1) If Santa Barbara Cottage Hospital must reduce the size and/or close a residency program due to disruption by emergencies, catastrophic events, or natural disasters the following policy/procedure shall be implemented to address interim recommendations promulgated by ACGME, RRC as well as an interim final rule published by CMS April 12, 2006 relative to Section 1135 of the Social Security Act and 42 CFR 412.105(a)(1)(l), 412.105(f)(vi), 413.75(b) and 413.79(f)(6). The aforementioned rule modifies existing regulations to provide greater flexibility to teaching programs in the event of disasters. The intent of the rule is to facilitate relocating residents affected as well as providing for guidance relative to Medicare GME funding during this type of disruption.
a) Once conditions prohibit maintenance of applicable ACGME standards and guidelines for graduate medical education, the Designated Institutional Official shall notify all Department Chiefs, program directors, ACGME, RRC and CMS.
b) The Department Chiefs and program directors shall maintain operational awareness of the location of residents and fellows within their programs as well as various points of contact for each individual within their program(s). This shall include email addresses and cell phone numbers (if available) for the trainees as well as provisions for notification of next of kin. The program director/designee shall take an immediate accountability of the location and welfare of all involved in the event of a disaster. The program directors will contact the DIO to confirm the safety of all trainees. The DIO will establish ongoing communication with program directors until a decision is made regarding the need to relocate trainees, either on a temporary or permanent basis. Once this decision is made, trainees will be notified in a timely fashion.
c) For program closure or reductions which are anticipated to be short term, the department chief and program director will assist the trainee to locate institutions which can provide temporary transfers so that the individual’s training is not interrupted. For any reduction/closure of any program thought to be long term or permanent, Santa Barbara Cottage Hospital shall make every effort to assist the trainees in identifying a program in which they can continue their education. If more than one program/institution is available for temporary or permanent transfer of a particular resident, the transferee preferences of each resident must be considered by the transferring program/institution. Programs will make the keep/transfer decision expeditiously so as to maximize the likelihood that each resident will timely complete the resident year. This shall be accomplished through contacting:
i) ACGME/RRC Suite 2000, 515 North State Street, Chicago, IL 60610-4322 Fax 312-755-7498 www.acgme.org
ii) A list of all approved programs can be found on the ACGME website, which will serve as a resource to identify programs in non-disaster affected areas which may be able to accept temporary or permanent transfers.
d) Within ten days after the declaration of a disaster, the designated institutional official (DIO) (or designee) will contact the ACGME to discuss due dates that the ACGME will establish for the programs (a) to submit program reconfigurations to ACGME and (b) to inform each program’s residents of resident transfer decisions. The due dates for submission are no later than 30 days after the disaster unless other due dates are approved by ACGME.
i) The DIO will call or email the Institutional Review Committee Executive Director with information and/or requests for information.
ii) Program Directors will call or email the appropriate RRC Executive Director with information and/or requests for information.
iii) Residents will call or email the appropriate RRC Executive Director with information and/or requests for information. On its website, ACGME will provide institutions instructions for changing resident email information in the ACGME Web Accreditation Data System.
e) Residents/fellows will continue to receive salary and benefits from Santa Barbara Cottage Hospital during temporary relocations. For program closures/disruptions that are permanent, residents will continue to receive salary and benefits until the trainee is placed and begins in another institution, or until the end of their contract.
f) Adherence to the following steps will expedite the process:
i) Initial identification and verification of personal information will be completed by the Program Directors and coordinators by September 1 of each year. The program directors will confirm the contact information for each resident.
ii) Searching and finding an accepting program for transfer: (1) Using the ACGME resources, responsibility for identifying a program will be shared by the resident, Department Chief, Program Director, and DIO.
iii) Transfer letters will be completed by the program Directors.
iv) The receiving hospital will be responsible for requesting resident complement increases from the ACGME.
v) The Director of Reimbursement (finance) will work with his/her counterpart at a receiving institution to assure that the process of transferring “capped” positions is implemented and GME funding is transferred.
1) Disaster: An event or set of events causing significant alteration to the residency experience at one or more residency programs.
COTTAGE HEALTH POLICY
RECOMMENDED BY: A. Gersoff, MD DATE: 11/14
ORIGINAL POLICY EFFECTIVE DATE: 8/07
APPROVED BY: E. Wroblewski, MD DATE: 11/17
DATE REVISED: DATE REVIEWED: 1/12, 11/14, 11/17