Billing Medicare for Locums work in a Residency Program

Coastal Coders
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Hi All,

We have a couple of physicians who are leaving our practice. This is a General Surgery/Trauma Practice. We are in the second year of our residency program training new trauma surgeons. Management is looking to fill the void of the departing surgeons with locums while they recruit new surgeons.
I am unable to locate any definitive information from Medicare about using locums (who, I am assuming, will not be part of the residency program) and billing Medicare under the other physicians NPI inside a residency program.
Any thoughts or direction on where to look for information would be greatly appreciated.
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A locums can only be used as a "substitute" for the physician who is not there, not longer than 60 days, and has to see the absent provider's patients (generally speaking). For example, if Dr. A is part of the residency program and is leaving, the locum Dr. B would fill in that specific opening and perform the associated duties specific to the absent provider. You'd wind up in a big mess with the whole residency factor I think. Even if you shifted existing providers around so that the "open" spots are non-residency related, I doubt you'd meet the locum requirement of who is considered an absent provider.

I don't know if this is an option, but maybe shifting the existing providers around, moving them into the program, and then picking up some independent providers to fill in the newly created non-residency openings might be the route to go.

No matter what, it's messy all around. I work at a large teaching facility and at times I just want to bang my head against a wall when problems like this come up.

Here's some links, although I don't know that they'll be that helpful.