Anesthesia Coding Alert

Modifier Update:

Stay Atop These Medicare Changes to Locum Tenens Guidelines

Published on Thu Apr 07, 2022

Modifier QC is still valid — but under a new name.

If your anesthesia practice is like most others, you have long turned to temporarily hiring a substitute physician to fill the gap when one of your regular physicians takes a leave of absence for vacation, health reasons, or other circumstances.

The term for this is locum tenens billing, which allows your practice to receive reimbursement for services provided by the substitute physician.

But: Although the service concept remains the same, Medicare guidelines have a new name for locum tenens billing. Here’s the latest on the new term, plus a quick refresher on key points to keep in mind when reporting these services.

The Latin Definition Says It All

“Locum tenens means ‘to hold the place of’ in Latin,” explains Laureen Jandroep, CPC, COC, CPC-I, CPPM, founder/ CEO of CCO.us. “When you bill for locum tenens, you are billing for a covering physician as if they were the regular physician. Medicare has certain parameters that need to be met in order to bill locum tenens, and many other insurance companies adopt similar policies.”

Name change: The new Medicare-approved term for locum tenens billing is “fee for time compensation” (FTC), according to Jill Young, CPC, CEDC, CIMC, owner of Young Medical Consulting in East Lansing, Michigan. So although locum tenens might still be the way it’s referred to at your practice, you won’t likely see any reference to locum tenens in new Medicare guidance.

However, know that locum tenens and FTC are describing the same billing concept. (For the purposes of this article, we will refer to this billing practice as locum tenens/FTC.)

Best bet: Follow locum tenens/FTC rules for your Medicare providers, and check with private payers about best practices for billing a substitute physician’s services. They might follow Medicare’s lead on this issue, or they might have their own rules to follow for these physicians.

Don’t Employ Locum Tenens/FTC As Extra Help

Remember, locum tenens/FTC is only for physicians that are “holding the place of” another physician. If you’re hiring a physician on a temporary basis for any other reason, you can’t use locum tenens/FTC billing to report the physician’s services.

Also, your locum tenens/FTC claims should include 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); append it to every code on every claim you file for a locum tenens/FTC physician.

Medicare ID alert: When you’re billing for a locum tenens/ FTC physician, they should use the name and National Provider Identifier (NPI) of the physician they’re substituting for. For example, let’s say Dr. LT is a locum tenens/FTC physician filling in for Dr. X. On their claims, Dr. LT would use Dr. X’s name and NPI.

Observe Locum Tenens/FTC Time Limit

Remember that a locum tenens/FTC doctor can fill in for 60 continuous days starting with their first date of service. “If coverage is needed for longer than 60 days, then the covering physician should be added to the group and their NPI number be used instead of the regular physician,” explains Jandroep.

You’ll also need to note that under the new “fee for time compensation” model, “it is required by Medicare that a separate log of patients and dates of service is kept for anyone seen by a locum tenens physician,” says Young.