Clinical and Education Work Hours Policy

Description of work hours requirements and regulations, with which University at Buffalo (as an ACGME-accredited sponsoring institution), its sponsored programs, and its residents/fellows must comply. This policy is published on the University at Buffalo Graduate Medical Education (UB GME) website and is available for review by residents/fellows at all times.

UB GME and its affiliated hospitals support a work environment that is safe and conducive to learning. Compliance with the Accreditation Council for Graduate Medical Education (ACGME) requirements and New York State Department of Health (NYS DOH) regulations on work hours contributes to such an environment. Wherever conflict exists between ACGME requirements and NYS DOH regulations, residents/fellows and faculty in UB-sponsored training programs must adhere to the more stringent requirement/regulation (see NYS – ACGME Post-Graduate Trainee Work-Hour Regulations Comparison Guide at the bottom of this policy). The clinical environment must be conducive to resident learning and support acquisition of knowledge, skills, and attitudes identified by the ACGME.

The UB Graduate Medical Education Committee (GMEC) oversees resident/fellow clinical and educational work hours, consistent with ACGME Institutional, Common and specialty-/subspeciality-specific Program Requirements and NYS DOH regulations, across all programs. UB GMEC oversees compliance with requirements and regulations by:

• Reviewing internal data on a schedule appropriate to the compliance history of the program (continuously or semi-annually) and as determined by the GMEC and/or the DIO. Data reviewed include but are not limited to:
  • Work hours data logged by residents/fellows via the RMS, including program director responses to potential violations flagged by the RMS
  • Anonymous Ethics Point reports from residents/fellows
  • Program Special Reviews (sequential meetings with residents/fellows, program leadership)
  • ACGME Annual Resident Survey
• Reporting persistent non-compliance to the Dean, Jacobs School of Medicine and Biomedical Sciences; Department Chairs; and/or hospital leadership (e.g., Hospital Official for GME, CMO, or equivalent)

• Reporting concerns pertaining to work hours and/or other learning environment issues by notifying their program director, chief resident, and/or the Designated Institutional Official (DIO); or by submitting concerns anonymously via Ethics Point.
• Notifying their supervising faculty physician immediately if circumstances (e.g., patient emergency) may lead to violation of work hours regulations.
• Timely, accurate and complete logging of work hours via the Residency Management System (RMS) in accordance with institutional and program guidelines.
• Providing complete information regarding their work hours and supervision to representatives of the sponsoring institution, ACGME, affiliated hospital administration, and/or Department of Health (IPRO), when requested.

• Monitoring resident work hours in accordance with ACGME requirements, NYS DOH regulations, and UB GMEC determinations. This must include, at minimum:
  • Ensuring that residents log work hours in the RMS as directed by UB GMEC
  • Monitoring resident work hours logged in the RMS as directed by UB GMEC
  • Providing timely, accurate, and complete information to UB GMEC and its subcommittee(s), ACGME, and IPRO as requested
• Reporting concerns pertaining to work hours and/or other learning environment issues to the DIO

Wherever conflict exists between ACGME requirements and NYS DOH regulations, residents/fellows and faculty in UB-sponsored training programs must adhere to the more stringent requirement/regulation (see NYS – ACGME Post-Graduate Trainee Work-Hour Regulations Comparison Guide at the bottom of this policy).

ACGME Institutional Requirements effective 7/1/2022:

• Clinical and Educational Work Hours: The sponsoring institution must maintain an educational work hour policy that ensures effective oversight of institutional and program-level compliance with ACGME clinical and educational work hour requirements. (Core) (IV.K.)

ACGME Common Program Requirements (Residency) effective 7/1/2022 (VI.F.1.-VI.F.4.b)):

• 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)

• Mandatory Time Free of Clinical Work and Education
  • The program must design an effective program structure that is configured to provide residents with educational opportunities, as well as reasonable opportunities for rest and personal well-being. (Core)
  • Residents should have eight hours off between scheduled clinical work and education periods. (Detail)
    • There may be circumstances when residents choose to stay to care for their patients or return to the hospital with fewer than eight hours free of clinical experience and education. This must occur within the context of the 80-hour and the one-day-off-in-seven requirements. (Detail)
  • Residents must have at least 14 hours free of clinical work and education after 24 hours of in-house call. (Core)
  • Residents must be scheduled for a minimum of one day in seven free of clinical work and required education (when averaged over four weeks). At-home call cannot be assigned on these free days. (Core)
• Maximum Clinical Work and Education Period Length
  • Clinical and educational work periods for residents must not exceed 24 hours of continuous scheduled clinical assignments. (Core)
    • Up to four hours of additional time may be used for activities related to patient safety, such as providing effective transitions of care, and/or resident education. (Core)
      • Additional patient care responsibilities must not be assigned to a resident during this time. (Core)
• Clinical and Educational Work Hour Exceptions
  •  In rare circumstances, after handing off all other responsibilities, a resident, on their own initiative, may elect to remain or return to the clinical site in the following circumstances:
    • to continue to provide care to a single severely ill or unstable patient; (Detail)
    • humanistic attention to the needs of a patient or family; or, (Detail)
    • to attend unique educational events. (Detail)
  • These additional hours of care or education will be counted toward the 80-hour weekly limit. (Detail)

NYS residency/fellowship programs are not eligible for rotation-specific exceptions to the 80-hour work week.

Established:  1994
Reviewed by GMEC: 10/94; 03/02; 03/03; 05/03; 09/03; 05/04; 08/04; 02/08; 07/11; 10/12; 06/17; 02/18; 02/21; 05/22