Get the Most Out of Locum Tenens Physicians

By Delly Parham, CPC
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Using locum tenens physicians to fill in for regular physicians may cost your practice instead of helping it if you don’t understand how to bill for their services. To ensure you get paid and stay in compliance, you must adhere to Medicare and commercial payer guidelines.

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Practices usually use locum tenens (Latin for “lieutenant”) physicians when the regular physician is absent because of vacation, illness, childbirth, business, education, active duty, or having left the practice. The advantages of hiring a locum tenens physician versus using a physician in the same practice or in the same area are that it:

  • Retains the regular physician’s existing patients
  • Introduces new patients to the practice
  • Maintains the patient level
  • Keeps revenue with the regular physician

Most practices using the services of a locum tenens go through a recruiting agency, such as Comp Health. These companies handle the licensing requirements, professional liability insurance, and screening of the locum tenens, taking the liability and burden off practices. The practice or group pays the recruiting agency, and the agency pays the locum tenens physician. If your practice chooses to hire the locum tenens directly, you must:

  • Check your state licensing laws for licensing requirements. Most – if not all – states require physicians to be licensed in that state.
  • Check with your professional liability insurance carrier.
  • Make sure the locum tenens is in good standing and get his or her professional liability insurance certificate, verifying it covers the services the locum tenens will be performing for the regular physician.

Whether you use a recruiting agency or hire the locum tenens physician directly, the practice must:

  • Train staff with information about locum tenens physician to retain patients with the regular physician and give them incentive to see locum tenens without fear, for example:
    • The locum tenens is temporary and will only see them once or for a short period of time.
    • The locum tenens’ experience and expertise as a physician.      

The period for which a single locum tenens physician may substitute cannot be more than 60 continuous days. The 60-day period begins the first day the locum tenens physician provides services for Medicare patients of the regular physician. An exception to this 60-day rule is for regular physicians who are called to active duty in the armed forces. The time is unlimited. See Social Security Act at section 1842(b)(6)(D.)

The regular physician:

  • Must schedule appointments under his or her schedule.
  • Is the only physician who can break the locum tenens’ 60-day period.
  • May re-set the 60-day period by returning to practice and see patients only one day after the initial 60-days and use the same locum tenens.
  • Must bill for the services of the locum tenens.
  • Must put his or her National Provider Identification (NPI) number on all filed claims.
  • May use more than one locum tenens to substitute for absences during the 60-day period.
  • May reimburse the locum tenens a fixed amount per diem or similar fee for time.
  • Must keep a record of each service furnished by the locum tenens physician and the NPI.

A locum tenens physician:

  • Fills in for the regular physician for 60 continuous calendar days.
  • Can substitute only if the regular physician is absent for any of the reasons above.
  • Cannot substitute more than 60 continuous calendar days, unless there is a break in the 60-day by the regular physician.
  • Cannot re-set the 60-day clock by taking a day off.
  • Generally does not have a practice of his or her own and moves from area to area as needed.
  • Is usually an independent contractor of the regular physician or group rather than an employee.
  • Does not have to be enrolled in the Medicare program to see Medicare patients
  • Cannot be a non-physician practitioner (e.g., NPs, CRNAs, PAs).
  • Cannot bill Medicare for services within the 60-day continuous period in his or her name or NPI.

The regular physician bills and receives payment from Medicare and other payers who follow Medicare’s guidelines for the locum tenens physician’s services as though the regular physician performs the services. The regular physician must put the regular physician NPI in box 24J and his or her name in box 31 of CMS 1500 and the regular physician or group name and NPI in box 33 of the CMS 1500. Other Medicare rules include:

  • Use the name and NPI of the regular physician or group.
  • Use modifier Q6 after the procedure code (Q6 identifies services by locum tenens physician).
  • If the only service a locum tenens physician performs is post-operative for an operation within a global period, it cannot be billed with Q6 modifier because the regular physician is paid a global fee, and it’s not necessary to include the service on the claim.
  • If a regular physician requires the locum tenens physician to provide services for longer than 60 continuous days without a break, the locum tenens physician must enroll with the practice.

Other payers have different rules. TRICARE requires that non-contracted locum tenens physicians complete a certificate or other document to be linked to the regular physician or group tax identification number. Some Medicaid programs (e.g., Florida Medicaid) require the locum tenens physician bill under his or her own name and NPI. Blue Cross Blue Shield adheres to the guidelines of Section 125b of the Social Security Act.  (BCBS Manual for Physicians and Providers, May 2010).

Source:

Medicare Claims Processing Manual, chapter 1, section 30:2.11

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14 Responses to “Get the Most Out of Locum Tenens Physicians”

  1. Patsy Williams says:

    Our surgery practice hires surgeons through different Locum Tenens Companies. We have used them in the cases of a physician absence like vacation and childbirth, and billed using the Q6 Modifier. We have also used them to augment regular staff. It is my understanding that the latter situation is not covered under the Locum Tenens billing rules and that it would be inappropriate to use the Q6 Modifier. The regular physician is not “absent” and the contracted physician is filling in gaps in the schedule. Therefore the only way to bill correctly for the contracted physician would be to have them credentialed. Does anyone have any guidance or references on this? Our practice is a very large multi-specialty organization. I am just a coder/biller and do make any decisions regarding credentialing. Does anyone who does credentialing know if this would be cost effective? These physicians are doing major surgeries and we will have to just take a loss on the services they perform.

  2. Diana McDonnel says:

    I work in a Hospitalist Department. We use locums to cover “gaps” in doctor coverage. We credential them and bill under their name and do not use a modifier.

  3. M Barnes says:

    Patsy, I have researched this thoroughly through the years, and locums should not be used other than “in place of” a credentialed physician. The practice would need to keep record of the regular physician’s reason for absence as stated in the article: vacation, illness, etc. All other physicians should be individually credentialed.

  4. Sue Marre says:

    We have a provider who is part of the group’s “pool” but we would like to use as a locum to fill a much needed vacancy at another location. Can we use this provider as a locum in this situation? Thank you.

  5. M Kelly says:

    If a provider terminates with our medical group and we employee a locum tenene physician, what are the guidelines in this situation? Can you use a locum physician after the 60day limit and if so what are those guidelines?

  6. D Parham says:

    Sue Marre,
    If the physician is part of the group’s pool and credentialed and is billing for services under the group tax id, that physician should be able to cover at your other location if the physician is licensed in the state of the other location, if the other location is a different state. He/she would not be considered a locum tenens physician.

    Kelly,
    If a provider terminates with your group, if the locum tenens physician provides services beyond 60 continuous days, the locum tenens will then have to join your group and be credentialed as part of your group. All services after the 60 days by that physician cannot be billed under the locum tenens guidelines outlined in the article.

    Hope this answers your questions.

  7. LenRNCPC says:

    We have a locum tenens who is currently working in our ambulatory surgery center (original physician has terminated with our practice and won’t be back) — can locum tenens work in surgery center?? We are having a hard time trying to figure out who needs to sign off on the “medical director” credentialing paperwork for the surgery center since the ASC guidelines are so strict. Any advise is much appreciated! Thanks.. len.

  8. Chris Ballesteros says:

    I have a provider who has terminated his contract with my multispecialty group. He is the only cardiologist on staff and I would like to hire a locum tenens as to not interrupt the cardiology services in my practice. Can I bill for the locum tenens under my group NPI with the Q6 modifier, even though the provider they are “covering” for will no longer be a part of my practice? I have a new cardiologist that won’t be able to be in practice until 45 days from now.

    Thanks,

    CB

  9. Joyce Casella says:

    For services and drugs provided in a Hospital Out-Patient Facility” (pos 22), must the Q6 modifier be applied to each line item (I am specifically talking about oncology services)? The drugs and administraion charges are submitted on UB forms. Would those items be billed under the absent physician or the locum?

  10. Len Hales RN CPC says:

    Joyce, I have researched locum tenens billing in outpatient facility setting thoroughly recently and you would NOT put the Q6 modifier on ANY facilty charge (ASC, Hosp outpatient) — I am only referring to the facility charge, not professional charges.

  11. Linda C. says:

    I have been offered a locum tenens position as a pediatrician in New Mexico. The practice would like to hire me directly, without an agency. This would be the first time I’d be working as a locum so I would like to know what the practice should provide for me. Insurance?, and what are the usual wages?

  12. Diane says:

    One of our ED physicians passed away. We would like to bring in a locum tenens until another physician can be hired. If this time is greater than 60 days, would this situation qualify for the six months as if the temporary physican is taking over for a terminated physician or one that has left the practice voluntarily? We are located in Alabama.

  13. Cindy W says:

    We have a locum coming for a short period of time. This is a new thing for our practice. Is there a certain verbage in the transcription that we need to utilize? (dictating with, for etc.) Does the Locum sign all notes? Any information would help. I have researched Medicare and cannot find any information on the transcription requirements.

  14. Tawana says:

    If one of our physicians is out can two locum tenens be hired? One to oversee Outpatient services and One for Inpatient services?

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