Medicare Compliance & Reimbursement

Hiring a locum tenens doesn’t need to be daunting and is actually a great benefit to practices and providers in need. Some of the guidelines, however, are a bit restrictive and confusing.

Locum review. Locum tenens describes a one-way exchange between providers. Your physician would retain a substitute physician to take over the practice for such reasons as illness, pregnancy, vacation, or continuing medical education. The substitute physician generally is paid a fixed amount per diem or similar for-time basis. To report the locum tenens services, you would append modifier Q6 to all of the temporary physician’s claims and bill under your physician’s (whom the locum is replacing) NPI. CMS limits both of these modifiers to 60 days of use per fill-in physician.

Here’s why reciprocal billing is different. Reciprocal billing, on the other hand, is a two-way exchange and utilizes a different modifier. For example, your physician and another doctor agree to see each other’s patients on weekends off and agree to a reciprocal billing agreement. These services would fall under modifier Q5. In these situations, the doctor who “owns” the patients, not necessarily the one who saw them at those visits, bills out the provided services under his NPI and appends modifier Q5 to indicate he really did not see the patient. The physicians don’t exchange any money because the services will even out over time.

Here are a few takeaways on the matter of locum tenens and reciprocal billing:

• There is no wiggle room on the 60 continuous days. The Noridian MAC recommends in instances where you might be out for a significant amount of days due to a sabbatical or in and out a couple days a week, you should contract a regular Medicare physician to cover for your absence.
• Locum tenens cannot be hired to cover for deceased regular physicians because when the provider passes away, his NPI and PTAN are deactivated. Locum tenens can only be used for living physicians.
• A locum tenens cannot be utilized for high volumes, overbooking, or practice expansions.
• Reciprocal billing allows for doctors to switch-hit, covering each other’s time off—it is a mutual exchange and benefits both parties.
• To use modifiers Q5 and Q6, your doctor must be unavailable to provide services. This means that your physician should be out of the office while the substitute physician provides services.
• Don’t confuse the modifiers—Q5 for reciprocal billing and Q6 for locum tenens—or your claims will be denied.