Oncology & Hematology Coding Alert

Question: Is it true that a locum tenens may only serve as a locum tenens for 60 days under Medicare?


New York Subscriber

Answer: Yes, but this rule is trickier than it sounds. If a substitute doctor, or locum tenens, serves in your practice and sends in claims under the absent physician's numbers, for Medicare you have a 60-day clock that starts on the first day of service. And it doesn't matter whether the locum tenens provides services every day for 60 days or once a week for 60 days--at the end of 60 days, the clock stops.

Pitfall: Some practices will code a substitute physician's services with Q6 (Service furnished by a locum tenens physician) for many months, reasoning that the substitute physician worked only once in a while, resetting the clock every time there's a break in services. This may be noncompliant billing.

Medicare instituted the 60-day limit for both locum tenens and reciprocal billing arrangements so it knows exactly who is providing care to its beneficiaries. If you-re going to use a substitute for more than two months, that physician should have his own ID number so you can identify him on your claims.

Medicare also favors providers having their own ID numbers to prevent a locum tenens arrangement from hiding a Medicare-excluded provider behind your physician's number. It is your practice's responsibility to ensure that the physician working in a locum capacity is not an excluded provider.

You may be tempted to continue reporting a substitute physician's services as locum tenens if she regularly fills in at your practice, but always for a different doctor. While there may be a technical argument that says this is fair use, you should remember Medicare's intent in creating the 60-day rule.
 
Don't forget: The locum tenens provision doesn't apply to -extra- physicians brought in to cover peak times. Locum tenens only applies to a physician who is substituting for a physician who is unavailable due to circumstances such as vacation, conference attendance, or pregnancy leave.