GME Policy on Substantial Disruptions in Patient Care or Education

I. PURPOSE

Best practices and the Accreditation Council for Graduate Medical Education (ACGME) require that every Sponsoring Institution (SI) has a written policy consistent with ACGME Policies and Procedures to address support for Graduate Medical Education (GME) programs and residents/fellows in the event of a disaster or other substantial disruption in patient care or education. The policy must include information about assistance for the continuation of salary, benefits, professional liability coverage, and resident/fellow assignments.

II. POLICY

New York Medical College (NYMC) will maintain and ensure support for the Residents and Fellows enrolled in its GME programs in the event of a substantial disruption in patient care or education.

III. SCOPE

This policy applies to all ACGME- or CODA-accredited or recognized programs sponsored by NYMC.

IV. DEFINITIONS

Resident refers to any person enrolled in a residency program accredited by the ACGME or CODA and sponsored by NYMC.

Fellow refers to any person enrolled in a fellowship program accredited by the ACGME and sponsored by NYMC.

ACGME is the Accreditation Council for Graduate Medical Education.

CODA is the Commission on Dental Accreditation.

DIO is the Designated Institutional Official.

GMEC is the New York Medical College Graduate Medical Education Committee.

Sponsoring Institution is New York Medical College.

Core Competencies are the areas of resident or fellow skill development and performance evaluated by the training program at least twice annually. These areas include: Patient Care, Medical Knowledge, Professionalism, Interpersonal and Communication Skills, Practice-based Learning and Improvement, and Systems-based Practice.

Disaster refers to an event or set of events causing significant alteration to the residency experience at one or more residency or fellowship programs.

Emergency Categorization for ACGME-accredited and recognized programs is a program status designated by the ACGME upon approval of a request submitted by a Program Director, with approval by the DIO, due to substantial and sustained disruption of GME operations resulting from a local surge of COVID-19, RSV, influenzas’, or similar occurrence. Emergency Categorization status can only be requested after a program, in collaboration with its clinical leadership, has first exhausted all other actual and potential sources of clinical support and when disrupting the GME experience to meet patient care needs is a last resort. The ACGME will allow programs with Program Emergency Categorization temporary relief from program requirements except for those pertaining to: patient and resident/fellow safety (including access to COVID-19 testing); clinical and educational work hour requirements; adequate resources for education/training; adequate supervision; and fellows functioning in their core (primary) specialty (not applicable to residency programs). Additionally, program accreditation/recognition site visit postponements can be requested. Programs with emergency characterization must continue to assess residents and fellows in all six Core Competencies, and such assessments must form the basis for decisions regarding promotion to subsequent appointment levels or satisfaction of requirements for program completion. Programs should follow the principles of competency-based medical education, as described to make determinations regarding the advancement, graduation, and board eligibility of individual residents and fellows. Emergency Categorization is requested in intervals, up to 90 days in a single academic year.

For CODA-accredited programs, Emergency Categorization is an internal NYMC classification applied to a program by the DIO in collaboration with the program director and the Vice Chancellor of Interprofessional Dental Education. This categorization prompts action by the program and DIO as per this policy.

Extraordinary Circumstance refers to an event or set of events causing significant alteration to the residency experience in one or more residency or fellowship programs. An extraordinary circumstance may or may not result in disruption in the provision of patient care within a residency or fellowship program or throughout multiple residency or fellowship programs and hospital departments. Examples of extraordinary circumstances include abrupt hospital closures, natural disasters, or a catastrophic loss of funding. An extraordinary circumstance prompts communication by the DIO, and program director(s) as applicable, to the ACGME or CODA.

Hospital refers to the hospital or other clinical site employing residents or fellows.

Temporary Transfer refers to a planned time-limited placement of a resident or fellow into another program/institution until such time as the program is able to return to the provision of an adequate educational experience.

Permanent Transfer refers to the transfer of a resident or fellow into another program where they are planning to complete their training program.

V. PROCEDURES

A. If an event, or set of events, causes significant alteration to the Residents’ or Fellows’ experience in one or more residency or fellowship programs, the DIO and the GMEC will abide by institutional and applicable ACGME and/or CODA policies and procedures for Emergency Categorization and Extraordinary Circumstances.

B. If the DIO, after consulting with the applicable program director(s) and Hospital leadership believes that an Extraordinary Circumstance has occurred, the DIO will then contact appropriate NYMC, ACGME, and/or CODA officials.

C. If the DIO, in consultation with the GMEC, determines that a program or Hospital cannot provide an adequate educational experience for Residents or Fellows because of the disaster, both individual programs and NYMC, in collaboration with pertinent Hospital leadership, will make best efforts to facilitate rotation reassignments, temporary transfer, or permanent transfer of Residents or Fellows, as appropriate. When necessary, the DIO, in consultation with the applicable program director(s) and Hospital leaders, may recommend permanent reductions in program complement or program closure (Please refer to related information in the GME Policy on Closures and Reductions.

D. When an Extraordinary Circumstance is identified, the DIO will be the primary contact with the ACGME or CODA to provide information for posting on the accrediting body website or in their materials, as applicable. The DIO is responsible for overseeing adherence to ACGME and CODA policies regarding all such events.

E. Whenever possible, the DIO will work with the program director and Hospital leaders in an effort to evaluate and arrange rotation reassignments to avoid Resident or Fellow transfers.

1. Priority will be given to secure rotation reassignments in the following order:

a. within other NYMC-sponsored programs;
b. other sites within the same hospital system;
c. NYMC affiliate programs;
d. other local hospitals; then
e. more distant hospital sites.

2. If rotation reassignments are inadequate to meet program needs, the DIO will work with the program director and Hospital leadership in an effort to arrange temporary transfer of some or all of the program’s Residents or Fellows to other programs or institutions, using the same prioritization, until such time as the program(s) can provide an adequate educational experience.

3. If temporary transfers are inadequate to address program needs, the DIO will work with the program director and Hospital leadership in an effort to arrange permanent transfers to other ACGME-accredited programs in which Residents or Fellows may continue their education.

F. If more than one program or institution is available for the temporary or permanent transfer of a particular Resident or Fellow, the preferences of the Resident/Fellow will be considered.

1. The DIO will work with programs and Hospital leaders in an effort to expeditiously reach decisions to reconstitute the program and/or arrange for temporary or permanent transfers of the Residents/Fellows to maximize the likelihood that each Resident/Fellow will complete the academic year with the least disruption to their education.

2. The DIO will ensure that ACGME and/or CODA policies and procedures are followed for new rotation sites and transfers of Residents and Fellows.

G. The DIO will communicate regarding temporary or permanent transfers through the ACGME and/or CODA, as applicable. The DIO will work with any programs receiving transferred residents in submitting the request for processing through the Accreditation Data System (ADS) for transfer of Residents and Fellows in ACGME accredited programs.

H. In the event of an Extraordinary Circumstance, NYMC will collaborate with Hospital leaders in an effort to provide continuing support, to the extent possible, for Residents and Fellows until the Hospital returns to normal operations or the Residents/Fellows are reassigned.

1. As feasible in the case of new rotation assignments to distant sites or temporary transfer, the Hospital will provide reasonable travel funding and assistance with temporary housing, to the extent possible and as determined by the sponsoring institution in collaboration with the Hospital.

2. The Hospital will also make all reasonable efforts to provide malpractice insurance for such rotations if the institution(s) at which the rotations are taking place is/are unable to provide the malpractice insurance.

3. As feasible, the Hospital will provide permanently transferred Residents/Fellows a reasonable relocation stipend to assist their transition to the new institution, as applicable and as determined by the sponsoring institution in collaboration with the Hospital.

I. DIO is responsible for the following:

1. Notifying members of the GMEC, the NYMC SOM Dean and/or Vice Chancellor of Interprofessional Dental Education (as applicable), NYMC public relations, and other appropriate members of NYMC leadership, of the Emergency Categorization or Extraordinary Circumstance and the impact, or anticipated impact, on residency and fellowship education.

2. Overseeing the submission of Emergency Categorization requests to the ACGME by the program director.

3. Contacting the ACGME and/or CODA with information and/or requests for information concerning the Extraordinary Circumstance as per accrediting body policies and procedures.

4. Maintaining accessibility of NYMC GME Office Staff and communicating contact information and methods to program directors and applicable Hospital leaders.

J. Program Director(s) are responsible for:

1. Promptly alerting the DIO to the need, or potential need, for Emergency Categorization or Extraordinary Circumstance.

2. Maintaining updated contact information, including a secondary e-mail address and emergency contact(s) with NYMC.

3. Keeping the DIO apprised of the evolving status of the program, hospital, and community.

4. Keeping program Residents/Fellows, program staff, and program faculty apprised of the evolving status of the program and Hospital.

5. Responding promptly to residents/fellows, program faculty and staff, the Hospital, and NYMC, and provide reasonably requested information.

6. Directing communications to the DIO before sending such communication to the ACGME or CODA or providing such information to news sources or the public.

7. Notifying as soon as possible the emergency contacts and DIO of injured or ill Residents/Fellows or Residents/Fellows who are missing during an Extraordinary Circumstance.

K. Residents are responsible for:

1. Maintaining updated contact information, including a secondary e-mail address and emergency contact(s) with the program.

2. Keeping the program apprised of changes in status, such as the inability to report for duty, in the manner requested by the program.

3. Responding promptly to the program, hospital, and NYMC, and provide reasonably requested information.

VI. EFFECTIVE DATE

This policy is effective immediately.

VII. POLICY MANAGEMENT

Executive Stakeholder: Dean of the School of Medicine
Oversight Office: Office of Graduate Medical Education