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The Medical Billing Challenges of Locum Tenens

March 15, 2016

Locum_Tenens_billing.jpgLocum tenens physicians, when used correctly, can be a good source of additional revenues for practices if they understand the payment and billing requirements.

Locum tenens defined:

The term “locum tenens” is Latin meaning “(one) holding a place” and refers to contracted health physician providers who provide substitute services for  a regular physician who is either temporarily unavailable due to illness, vacation, pregnancy, or other valid reasons for a leave of absence, or who have left the practice altogether.  

The Centers for Medicare and Medicaid (CMS) have developed guidelines for qualifying and billing locum tenens providers; spending time studying their guidelines will pay off in increased revenues as well as reducing the chances of incurring penalties.

 Billing criteria for locum tenens

  • The regular physician of a patient treated by a locum tenens physician may submit a claim and be reimbursed for Part B (if accepting assignment) for covered visits.
  • The patient must seek the services of the regular physician.
  • The patient’s regular physician must be unavailable.
  • The physician pays the locum tenens physician on a per die or fee-for-time basis.
  • The locum tenens physician does not provide services beyond the 60-day limit.
  • Substitute physician services are identified on claims by using the modifier Q6 after the procedure code.
  • Do not bill for locum tenens services while awaiting physician credentialing by Medicare.
  • If post-operative services by a substitute physician are the only services performed by the substitute physician during a period covered by the global fee these need not be identified on the claim as substitute services.

According to information by the American Academy of Professional Coders (AAPC) certifying organization, a locum tenens physician cannot be part of a practice’s expansion program.

It is important to refer directly to the CMS Claims Processing Manual  for the most accurate and up-to-date information.

Group practices:

Billing requirements of subsection B need to be met in order for a medical group to be able to submit assigned and unassigned claims for services by locum tenens physicians for patients of a regular physician of the group.

  • The group should use the HCPCS modifier Q6 after the procedure code on form CMS-1500, item 24d.
  • For these purposes, a per diem or other fee-for-time method of compensation by the group to   the locum tenens physician is considered paid by the regular physician.
  • If a physician has left the group, the group may engage and bill for a temporary replacement locum tenens physician for up to 60 days.
  • Regarding reciprocal billing arrangements: claims submission requirements are the same for both assigned and unassigned claims.

Exception to the time limit:

Section 116 of the “Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSE)” extended the 60-day limit for substitute physician billing for physicians called to active duty in the Armed Forces for services rendered from January 1, 2008 through June 30, 2008.  

Commercial carriers

The Medicare rule applies only to Medicare and physician services; before billing a commercial carrier you will need to know whether they adopted Medicare’s locum tenens rule. Many commercial carriers will not compensate for a non-credentialed physician, even if locum tenens.

Where to find additional help with locum tenens claims

Although billing for locum tenens may appear complicated at first glance, it can be well worth your while to implement the correct billing procedures for reimbursement of this important source of additional revenue. For assistance with documenting and billing locum tenens and other billing issues, working with a professional experienced claims and documentation management service can pay off handsomely in terms of captured revenues and time saved. Contact M-Scribe Technologies, LLC, for more information about how we have helped practices of all sizes and specialties with their claims and documentation needs, ensuring full compliance while improving reimbursement rates.


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