Medicare Compliance & Reimbursement

Prep now for summer FFT fill-ins, previously called locum tenens.

Summer vacations are still in full swing, which means many of your care providers will be taking time away from the practice. If they plan to hire fill-in physicians to take their places, then you may be employing a process called fee-for-time (FFT) billing, previously referred to as locum tenens.

To ensure you’re reporting these services the right way, check out one truth and seven common myths about FFT billing.

Truth 1: FFT Billing Applies to Temporary Doctors

Collecting FFT compensation may be appropriate in situations when a substitute physician provides services in lieu of the regular physician because the latter is unavailable. You have to append modifier Q5 (Service furnished under a reciprocal billing 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) or Q6 (Service furnished under a fee-for-time compensation arrangement by a substitute physician …) to all of the temporary doctor’s claims.

In black and white: “The A/B MAC [Medicare Administrative Contractors] 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 FFT basis, and certain other requirements are met,” the Centers for Medicare & Medicaid Services (CMS) says in Chapter 1 of the Medicare Carrier’s Manual.

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

“When you’re billing using FFT, do not use the fill-in physician’s national provider identifier [NPI] for your claims. Instead, report the fill-in doctor’s services under the NPI of the physician they are replacing, with modifier Q5 or Q6 appended to the codes,” advises Johnson.

Many 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 FFT 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, you should simply follow the rules and always use FFT modifiers 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, FFT 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 modifiers Q5/Q6. In reality, if you’re using FFT 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 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.