Billing NP Incident to a Locum Tenens Physician

[JulieDcpc]

Knowing that the Locum Tenens provision does not apply to mid-levels, does anyone have an answer for the following scenario?

Practice with 2 physicians, 1 NP, 1 PA.
Currently bill NP and PA charges as "Incident to" the physician in the office at time or service.
One physician is leaving practice.
Using a Locum Tenens physician to cover that physician.
Will bill his services following the Locum Tenens guidelines (modifier Q6 and NPI of physician he is replacing).

Question is: can we bill the NP and PA services "incident to" the Locum Tenens physician? (The claim would have the Q6 modifier, the NPI of the physician who left the practice.)

I have read CMS Locum Tenens guidelines, but it is not clear to me that this scenario is described.

Thanks.