Changes to Reciprocal Billing and Locum Tenens Arrangements

As a result of the “21st Century Cures Act” (P.L. 114-255), reciprocal billing arrangements and locum tenens arrangements will apply not only to physicians, but to physical therapists (specialty code 65) who work in certain health professional shortage areas. With the passing of this law, both reciprocal billing arrangements and locum tenens arrangements are applicable to Medicare-enrolled physical therapists who use substitute physical therapists to furnish outpatient physical therapy services.

To apply, the outpatient physical therapy services must be furnished in a health professional shortage area (HPSA), medically underserved area (MUA), or rural area.

The term “locum tenens” is being changed to “fee-for-time compensation arrangement.” The descriptions for modifiers Q5 (reciprocal billing arrangement) and Q6 (fee-for-time compensation arrangement) will be amended to include physical therapists in addition to physicians and the description for the Q6 modifier with replace the term “locum tenens arrangement” with “fee-for-time compensation arrangement.”

The guidelines for reciprocal billing and “fee-for-time compensation arrangements (formerly locum tenens arrangements) may be found in the Medicare Claims Processing Manual Internet-Only Publication # 100-04, Chapter 1, Sections 30.2.10 and 30.2.11, respectively.

These changes are effective July 13, 2017.

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Maryann Palmeter

Maryann has over 30 years of experience in the healthcare industry with emphasis on federal and state government payer billing and compliance regulations. She is employed with the University of Florida Jacksonville Healthcare, Inc. as the director of physician billing compliance where she provides professional direction and oversight to the Billing Compliance Program of the University of Florida College of Medicine – Jacksonville. Maryann served on the AAPC's 2011-2013 National Advisory Board and the 2013-2015 Board as secretary. Palmeter currently serves the Jacksonville, Florida local chapter as education officer and has served as president, president-elect, and member development officer. Palmeter was named the AAPC’s 2010 “Member of the Year.”

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