Oncology & Hematology Coding Alert

Question: One of our physicians will be away for eight weeks. She has made locum tenens arrangements for another physician to cover while she’s away. There already is a nurse practitioner who bills incident-to under the regular physician. How do we bill the NP’s services while the locum tenens physician is supervising?

Virginia Subscriber

Answer: Incident-to requirements state that the supervising physician doesn’t have to be the physician who is associated with the plan of service. Any physician can supervise, as long as the nurse practitioner (NP) is acting as an extension of the plan created by a physician. While the billing requirement appears clear, you may want to verify any MD/NP collaboration agreement as well as the State Board of Nursing regulations regarding the collaborating physician substitute to ensure your practice is aware of all requirements. For instance, the practice should determine whether work during the physician’s absence under the locum tenens’s supervision will affect the collaboration agreement.

Example: The NP is providing incident-to services based on Dr. Normal’s plan. Dr. Locum is the locum tenens physician during Dr. Normal’s absence. File the claim with Dr. Normal’s name and identification numbers, and append modifier Q6 (Service furnished by a locum tenens physician) to indicate a locum tenens physician was present instead of Dr. Normal.

Caution: CMS has a 60-day time limit for using locum tenens physicians. If your physician will be gone longer than that, the physician should review options in advance for continuing patient care, keeping in mind an alternate option would be necessary after the 60-day mark.

You’ll find additional locum tenens information in the Medicare Claims Processing Manual, Chapter 1, Section 30.2.11, at www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c01.pdf. Your local J11 Part B MAC provides a "Locum Tenens and Reciprocal Billing" resource at www.palmettogba.com/palmetto/providers.nsf/docsCat/Jurisdiction 11 Part B~Publications~Physician-Supplier Guide. It provides pointers such as, "The regular physician must keep on file a record of each service along with the substitute physician’s NPI."