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Locum Tenens and Medical Billing Challenges

March 10, 2016

Locum_Tenens.jpgWhen physician and advanced practice staffing service surveyed practices who used locum tenens providers, they discovered that nearly one in five did not bill for their Locum Tenens services, potentially leaving a lot of revenue uncollected. The main reasons cited were that either administrators were not aware that they could bill for their services, or that they believed the billing process was too complex.

If your practice uses locum tenens providers, you can be reimbursed for their services in most cases, and the process is no more complicated than any other billing scenario. Here’s what you need to know to bill—and get paid for—your locum tenens services. 

Which Payers Reimburse for Locum Tenens Services?

The Centers for Medicare and Medicaid Services (CMS) has authorized Medicare to reimburse for locum tenens physicians if certain conditions are met, which are discussed below. Following their lead, most state Medicaid plans also authorize payment for Locum Tenens services. In some cases, states require you to enroll the Locum Tenens physician separately as a provider, check your state’s plans for details. 

When it comes to private payer contracts, most will allow you to bill under the contracted physician’s name and National Provider Identifier (NPI), but you should check your individual contracts for specific guidance. In some cases, your Locum Tenens physician will need to be credentialed separately. 

For payers with whom you are not under contract, it is usually a matter of simply billing under the regular physician’s NPI with no additional credentialing required. 

What Are the Limiting Conditions for Short-Term Locum Tenens Reimbursement?

If you are using Locum Tenens physician to cover for one of your regular providers who is absent due to short-term disability, vacation, continuing education or other situation that prevents him/her from seeing patients for a period of time, CMS allows you to bill for Locum Tenens services under the absent physician’s NPI as long as the following conditions are met:

  • The Locum Tenens is covering for an absent physician for a period of 60 continuous days or fewer. If the period exceeds 60 days, the Locum Tenens physican must be credentialed separately. 
  • The locum tenens physician is paid on a per diem or fee-for-time basis as opposed to fees for individual services provided. 
  • The credentialed physician must be physically unavailable to see patients and the Medicare beneficiary is seeking care from the absent physician. 

The 60-day allowance can be re-set for another 60 days if the credentialed physician returns to work for a period of time before taking another leave of absence. 

Are There Special Documentation Requirements for Billing?

The Locum Tenens physician must keep records for each service provided under the regular physician’s NPI; most experienced Locum Tenens physicans are familiar with the documentation requirements for reimbursement purposes. 

When completing the CMS-1500 form, services provided by an Locum Tenens physician must be designated with a Q6 modifier, which is entered in box 24D of the claim form the original physician’s NPI goes in box 24J, the rendering provider’s ID. 

Keep in mind that the billing guidelines for locum tenens physicians do not apply to the services provided by an Locum Tenens nurse practitioner or other non-physician provider. If you are contracting with Advanced Practice Provider (APP) to cover for an absent physician, contact your local Medicare administrative contractor for details on how to bill and whether the Q6 modifier is appropriate. 

What About Billing for Long-Term Locum Tenens Physicians?

If you are using Locum Tenens as part of your long-term staffing needs, perhaps during a physician search or to cover seasonal fluctuations in volume, you can still bill for their services. However, they will need to complete the credentialing process as a new physician for each payer you plan to bill for services. In this case, they may not use another physician’s National Provider Identifier (NPI) with the Q6 modifier.


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