Recently one of our clients asked us if they could use locum tenens while they were on vacation. As summertime approaches, this question may be on everyone’s mind, so it seems like a good time to review acceptable and unacceptable uses of a locum tenens. After all you don’t want to arrange for coverage of your practice and then not get reimbursed for the services rendered.
For Medicare eligibility and reimbursement, specific criteria must be met for a legitimate locum tenens, or fee-for-time compensation arrangement:
- The substitute provider can only bill under the regular provider’s National Provider Identifier, or NPI, number for 60 continuous calendar days, unless the regular physician was called to active military duty.
- The patients must seek the services of the regular physician.
- Claims submitted to Medicare must use the modifier “Q6,” to indicate the use of a locum tenens.
- The substitute physician must not be an employee, but an independent contractor.
- The substitute physician must be paid on a per diem or similar time basis.
What Are Acceptable Uses of a Locum Tenens?
Examples of acceptable uses for a fee-for-time compensation arrangement include the following scenarios:
- A physician takes a leave or goes on vacation. During that time, another physician sees that physician’s patients. Those visits can be billed to Medicare under the regular physician’s name, and Medicare will reimburse the regular physician as if she performed the services.
- A physician terminates from the group. While the group tries to recruit a replacement, a substitute physician covers that physician’s caseload for up to 60 days.
- Two locum tenens providers cover the panel of a physician on leave for 60 days, alternating the weeks they work.
What Are Unacceptable Uses of a Locum Tenens?
For Medicare purposes, the following are unacceptable uses of a fee-for-time compensation arrangement:
- If a physician dies, no one can bill under that physician’s name.
- Locum tenens arrangements for Medicare do not include nurse practitioners, physician assistants or any other provider type besides physician and physical therapist (in certain geographies or region). However, they do not need to be of the same specialty.
- A newly hired physician cannot bill as a locum tenens provider while pending Medicare enrollment; employees do not qualify.
- You are expanding your practice and need additional providers. A fee-for-time arrangement would not qualify, since there is no regular physician to substitute for.
- The regular physician cannot provide services elsewhere while a substitute physician also is billing under her credentials; the regular physician cannot be available to work.
The above rules apply to the Medicare program. Different insurance plans can have their own rules regarding the allowed use of a substitute physician, but most will follow Medicare. However, it is always a good thing to check with each carrier.