EM Coding Alert

Bust Locum Tenens Myths To Stay On Track

Hint: Never leave out modifier Q6 when you report a locum’s services.

Imagine this scenario: One of the physicians you work for, Dr. Johnson, a family practice physician, is diagnosed with breast cancer. She decides to take six weeks off while she goes through her first round of chemotherapy treatments.

Dr. Johnson chooses to bring in a locum tenens (LT) physician, Dr. Overman, to cover for her during her absence. How would you handle this situation?

If you want to make the most of your LT claims, read on for some expert input.

Know the ABCs of LT

Locum tenens means “(one) holding a place” in Latin. In the medical field, you bring in an LT physician to temporarily replace another physician who cannot be in the office for some reason such as vacation, illness, or maternity leave.

Don’t let the guidelines for using an LT physician trip you up. Join us as we shatter four common LT myths.

Myth #1: You can bill LT for non-physicians.

Truth: Although many practices may try to use a locum for other employees, you can only use LT when substituting for a physician (medical doctor [MD] or doctor of osteopathic medicine [DO]).

“One of the biggest problems I see is when practices try to bring in a locum tenens for a nurse practitioner or a PA (physician assistant) who is going to be gone,” says Maggie M. Mac, CPC, CEMC, CHC, CMM, ICCE, AHIMA-approved ICD-10 CM/PCS trainer and president of Maggie Mac-Medical Practice Consulting in Clearwater, Fla. “A locum tenens can be used as a replacement for a physician, not for anyone else.”

Bottom line: Never use an LT in place of anyone other than a physician.

Myth #2: It’s acceptable to neglect the time limit for LT.

Truth: The Centers for Medicare and Medicaid Services (CMS) sets a strict 60-day stipulation for using an LT physician.

Usually, an LT can fill in for the same physician for no longer than 60 continuous days, starting with the first day of service. The 60 days can include weekends, but the locum cannot skip days in between, then continue after the 60 days.

Exception: According to section 116 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSE), enacted on December 29, 2007, “the exception to the 60-day limit on substitute physician billing for physicians called to active duty in the Armed Forces has been extended for services furnished from January 1, 2008 through June 30, 2008 … a physician called to active duty may bill for substitute physician services from January 1, 2008 through June 30, 2008 for longer than the 60-day limit.”

“With many physicians being called up for military medical work, this is always an important exception to keep in mind,” says Suzan Hauptman, CPC, CEMC, CEDC, senior principal of ACE Med group in Pittsburgh, Pa. She worked with a physician who was in Iraq for nine months and having the LT on board was valuable in keeping the schedule full and patient satisfaction up.

Myth #3: Practices can hire an LT as “extra help.”

Truth: An LT provider can absolutely not be “hired” by the practice, according to Melanie Witt, RN, CPC, MA, an independent coding expert based in Guadalupita, N.M.

“The locum tenens physician is not an employee, and the practice pays a fee to the agency that employees the locum to come to the practice,” explains Witt. “It is treated as a contractual arrangement.”

Mac agrees, and points out that you cannot view locum tenens as “extra help” because in this situation, you must be temporarily replacing the physician. The original physician you are replacing cannot be seeing patients at the same time as the locum.

Remember: An LT physician usually has no practice of his own and moves from area to area as needed. The locum retains the status of an independent contractor, not an employee.

Myth #4: The modifiers are optional.

Truth: You must append modifier Q6 (Service furnished by a locum tenens physician) to any code for services the locum provides.

When you bill an LT physician’s services, you bill them under the physician he is replacing for that time period. Modifier Q6 tells the payer that the LT physician is practicing medicine on behalf of the original physician, who is not available to see patients. This also indicates that the situation is temporary. The modifier protects your physician in the event of an audit, because obviously your original physician didn’t perform those services — the locum did, explains Mac.

Caution: Take care that you don’t confuse modifier Q6 with modifier Q5 (Service furnished by a substitute physician under a reciprocal billing arrangement), which should not be used for LT billing. Q5 is for reciprocal billing and has nothing to do with LT.

Billing scenario solution: According to CMS’s guidelines and applying the rules to our above example, Dr. Overman, the LT physician, can only cover for the original physician, Dr. Johnson, for up to 60 days. You would submit the bill for the services under the absent physician’s ID (Dr. Johnson’s), while paying the locum per diem or an hourly rate. You must also append a Q6 modifier to any services the locum provides.