Medicare Compliance & Reimbursement

LT restrictions made easy with these tips for filling physician vacancies.

Twinkling lights, flu shots, and the arrival of packages in the mail can only mean that the holidays are fast approaching. With heightened travel time and family commitments on the horizon, it’s often necessary for practices to hire Locum Tenens (LT) physicians to provide coverage for doctors away on winter vacation.

Quick Review: “Locum tenens” (LT) refers specifically to physicians who substitute for other physicians when they’re absent for the following reasons: illness, pregnancy, vacation, continuing medical education, and sabbatical.

“Locum tenens do not generally participate in the Medicare program, often moving to wherever they’re needed,” said a Noridian Medicare representative during the MAC’s webinar entitled “Reciprocal Billing and Locum Tenens Arrangements.”

Securing an LT to fill in for an absent physician can really lighten the load around the office, but make sure you’re coding and hiring within the set LT parameters mandated by CMS.

Notes on the LT Substitution

NPI: It’s wise to remember that a locum tenens is substituting for a regular physician and is not a temporary hire for a busy practice—LTs are not contractual employees. In fact, though they may have their own National Provider Identification (NPI) numbers, LTs services are always billed under the regular physician’s NPI.

“You can mention the locum’s NPI number in the records, but it is not a requirement. If you do, put the locum’s NPI in block 19,” said the Noridian MAC representative during the session. “Always bill with the absent, regular physician’s NPI and make sure you reflect the locum in the documentation.”

60-day limitation: The arrangement always notes that an LT cannot work for more than 60 continuous days for the physician she is covering. That time period can include weekends, and the locum tenens cannot skip days during that time and then continue after the agreed-upon 60 continuous days. The only exception to this rule is when the regular physician is called to active duty, in which case the locum tenens’ time of service can be unlimited, explained the Noridian Medicare rep.

“A locum is allowed for 60 consecutive days for a physician,” says the Noridian rep. “If the regular physician is part of a group with many doctors, the locum can come back and work for a different physician when his 60 days are up.”

MD or DO only: There are medical restrictions when hiring locum tenens for your practice. CMS requires that the LT be an MD or DO, and there are no exceptions. “Non-physician practitioners cannot have locum during their absences,” says the Noridian rep. In addition to medical specialists like cardiologists, urologists and others, an LT can also be utilized in the areas of general medicine, osteopathy, podiatry, dental surgery, optometry, and chiropractic services.

Document to avoid audit: It is essential that the documentation is comprehensive and detailed to avoid confusion about the services rendered by the LT. The beneficiary’s care must be “within the authorized scope of the practice; a medical necessity for the visit must be met; and documentation must clarify that the provider of service was the locum tenens, along with documenting the billing provider,” Noridian Health Solutions said in its webinar presentation.

Billers don’t need to mention the NPI of the LT or his name on the claim, but the medical records must be clear and mention the LT, the service provided, and his NPI.

Watch Your Modifiers

It’s critical to bill under the name and absent physician’s NPI number to avoid denials. You need to append modifier Q6 (Service furnished by a locum tenens physician) to any code you’re using to cover the LT’s care. “This certifies to the MAC that you are following the locum rules when billing,” said the Noridian rep.

Code locum tenens accurately. When you report locum tenens services, don’t confuse modifier Q6 with reciprocal billing modifier Q5 (Service furnished by a substitute physician under a reciprocal billing arrangement). Reciprocal billing arrangements typically describe a two-way exchange between providers.

Honorable mention: It’s important to remember that an LT can be substituted for a “hospice patient’s attending physician,” but modifier GV (Attending physician not employed or paid under arrangement by the patient’s hospice provider) must be attached to the code along with modifier Q6.

Resource: For a review of the Noridian Health Solutions materials on locum tenens and other billing issues affecting Medicare, visit https://med.noridianmedicare.com/web/jeb/enrollment/inquiries-and-solutions.