Question: I know that CMS allows you to use locum tenens providers after a physician leaves a group practice for 60 days while you search for a replacement. Our physician who performed both anesthesia and pain services left, and we currently have two locums working in her place: one for anesthesia and one for pain management. If both locum physicians work the same day, how should we handle the billing?
New Hampshire Subscriber
Answer: Your first step is to ensure that the circumstances meet all required elements for reporting locum tenens services. According to a Medicare NHIC bulletin from February, 2007, "the group must keep on file a record of each service provided by the substitute physician, associated with the substitute physician's UPIN, and make this record available to the carrier upon request."
Next, keep a record of each patient (both anesthesia and pain management) seen by each of the locum tenens physicians. For practical purposes, you may be able to run a concise report showing all cases reported for the time period using modifier Q6 (Service furnished by a locum tenens physician). Identify both the anesthesia and pain physicians by National Provider Identifier (or NPI, which replaced UPIN), and keep the information with your documentation. Although it may appear only one physician is providing services and, therefore, overlapping pain and anesthesia procedures, documentation will support the locum tenens arrangement in place.