Cardiology Coding Alert

Hint: CMS has set a strict 60-day stipulation for using a LT physician.

Think you aced the LT coding challenge? Check your answers against these experts’.

Answer 1: False. Although many practices may try to use a locum for other employees, you can only use LT when substituting for a physician (medical doctor [MD] or doctor of osteopathic medicine [DO]).

“One of the biggest problems I see is when practices try to bring in a locum tenens for a nurse practitioner or a PA (physician assistant) who is going to be gone,” says Maggie M. Mac, CPC, CEMC, CHC, CMM, ICCE, AHIMA-approved ICD-10 CM/PCS trainer and president of Maggie Mac-Medical Practice Consulting in Clearwater, Florida. “A locum tenens can be used as a replacement for a physician; not for anyone else.”

Remember: Never use a LT in place of anyone other than a physician.

Answer 2: CMS has set a strict 60-day stipulation for using a LT physician.

Usually, a LT can fill in for the same physician for no longer than 60 continuous days, starting with the first day of service. The 60 days can include weekends, but the locum cannot skip days in between, then continue after the 60 days.

Exception: According to section 116 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSE), enacted on December 29, 2007, “the exception to the 60-day limit on substitute physician billing for physicians called to active duty in the Armed Forces has been extended for services furnished from January 1, 2008 through June 30, 2008 … a physician called to active duty may bill for substitute physician services from January 1, 2008 through June 30, 2008 for longer than the 60-day limit.”

“With many physicians being called up for military medical work, this is always an important exception to keep in mind,” says Suzan Hauptman, CPC, CEMC, CEDC, senior principal of ACE Med group in Pittsburgh, Pennsylvania. She worked with a physician who was in Iraq for nine months and having the LT on board was valuable in keeping the schedule full and patient satisfaction up.

Answer 3: You must append modifier Q6 (Service furnished under a fee-for-time compensation arrangement by a substitute physician; or by a substitute physical therapist furnishing outpatient physical therapy services in a health professional shortage area, a medically underserved area, or a rural area) to any code for services the locum provides.

When you bill a LT physician’s services, you bill them under the physician he is replacing for that time period. Modifier Q6 tells the payer that the LT physician is practicing medicine on behalf of the original physician, who is not available to see patients. This also indicates that the situation is temporary. The modifier protects your physician in the event of an audit, because obviously your original physician didn’t perform those services — the locum did, Mac says.

Caution: Take care that you don’t confuse modifier Q6 with modifier Q5 (Service furnished under a reciprocal billing arrangement by a substitute physician; or by a substitute physical therapist furnishing outpatient physical therapy services in a health professional shortage area, a medically underserved area, or a rural area), which should not be used for LT billing. Q5 is for reciprocal billing and has nothing to do with LT.

Answer 4: True. A LT provider can absolutely not be “hired” by the practice, according to Melanie Witt, RN, CPC, MA, an independent coding expert based in Guadalupita, New Mexico.

“The locum tenens physician is not an employee, and the practice pays a fee to the agency that employees the locum to come to the practice,” Witt explains. “It is treated as a contractual arrangement.”

Mac agrees and points out that you cannot view locum tenens as “extra help” because in this situation, you must be temporarily replacing the physician. The original physician you are replacing cannot be seeing patients at the same time as the locum.

Remember: A LT physician usually has no practice of his own and moves from area to area as needed. The locum retains the status of an independent contractor, not an employee.