ED Coding and Reimbursement Alert

In black and white: “The A/B MAC Part B may pay the patient’s regular physician for physicians’ services and services furnished incident to such services that are provided by a substitute physician during the absence of the regular physician where the regular physician pays the substitute on a per diem or similar fee-for-time basis, and certain other requirements are met,” the Centers for Medicare & Medicaid Services (CMS) says in Chapter 1 of the Medicare Carrier’s Manual’s (Source: http://www.cms.hhs.gov/manuals/downloads/clm104c01.pdf.)

Myth 1: You’ll Use the Fill-in Doctor’s NPI

When you’re billing using fee-for-time, you can’t use the fill-in physician’s national provider identifier (NPI) for your claims. Instead, you’ll report the fill-in doctor’s services under the NPI of the physician the fill-in is replacing, with modifier Q6 appended to the codes.

Many Medicare Administrative Contractors (MACs) require you to also include the NPI of the temporary doctor in box 23 on the CMS-1500 billing form. Check with your payers to confirm that this is how you should submit your FFT claims before submitting them.

Myth 2: You Can Bill Fee-for-Time Before Your Doctor Is Credentialed

Some practices get tired of waiting for a new physician’s Medicare credentialing application to process, so they report the new doctor’s services under an existing physician’s ID number with modifier Q6 appended. However, this is not appropriate.

In reality, FFT is designed to represent services performed in the absence of the regular physician, not as a temporary stopgap for new providers.

In fact, the Office of Inspector General (OIG) addressed this issue by offering the following example of “misrepresentation of services to the Federal health care programs” in the Oct. 5, 2000, Federal Register:

“When the practice bills for a service performed by Dr. B, who has not yet been issued a Medicare provider number, using Dr. A’s Medicare provider number. Physician practices need to bill using the correct Medicare provider number, even if that means delaying billing until the physician receives his/ her provider number.”

Myth 3: In Some Cases, You Can Skip Modifier Q6

Some practices will bill the fill-in physician’s services under the existing doctor’s NPI and just leave off the Q6 modifier, acting as if the other doctor personally performed the service.

Although some practices may try to slip under the radar this way, eventually the MAC will discover the discrepancy; so should simply follow the rules and always use modifier Q6 on your claims.

Myth 4: You Can Use FFT for “Extra Help”

If you’re hiring a physician on a temporary basis to assist during high-volume periods, you can’t use FFT billing to report the physician’s services. The fill-in doctors are not holding the place of the regular doctor, and therefore, fee-for-time billing doesn’t apply.

Myth 5: There’s No Time Limit on FFT

Having a new physician as a fill-in at your practice doesn’t allow you unlimited time reporting services using modifier Q6. In reality, if you’re using fee-for-time billing, you’re under a strict timeline of 60 continuous days. In rare cases when a physician is on active duty in the military, Medicare may allow you to bill FFT services beyond the 60-day limit.

If you need coverage is needed for longer than 60 days, then the covering physician should be added to the group and their NPI number should be used instead of the regular physician’s.

Myth 6: You Can Use FFT for Nonphysician Providers

Some practices use fee-for-time billing even when employing fill-in nurse practitioners or physician assistants, but that’s inappropriate. According to Part B Mac Noridian Medicare, “Services of non-physician practitioners (e.g., CRNAs, NPs and PAs) may not be billed under fee-for-time compensation arrangements or reciprocal billing reassignment exceptions … A regular physician is defined in this case as MDs or DOs.” (Source: https://med.noridianmedicare.com/web/jfb/specialties/locum-tenens-and-reciprocal-billing).

The only exception to this physician-exclusive requirement is that physical therapists in a health professional shortage area (HPSA), a medically underserved area (MUA), or in a rural area may be able to bill using fee-for-time.

Myth 7: FFTs Can Bill for Services Normally Included in Global Period

Some practices think there’s a loophole in the FFT process, allowing them to report services that would normally be included in a global period separately if an FFT doctor performs them. However, this is inaccurate. “If postoperative services are furnished by the substitute physician, the services cannot be billed with modifier Q6 since the regular physician is paid a global fee,” Noridian says.

Torrey Kim, Contributing Writer, Raleigh, N.C.