Ophthalmology and Optometry Coding Alert

Compliance:

Avoid Locum Tenens Audit Trouble With Documentation

Use computerization, special file to keep track of temp doctor

A locum tenens physician may be a temporary addition to your ophthalmology practice. But if you don't keep proper documentation, the headaches may last long after he is gone.

Billing for a locum tenens' services is fairly straightforward, experts say. You have to append modifier Q6 (Service furnished by a locum tenens physician) to all of the temporary doctor's claims and bill under the NPI of the physician the locum is replacing. Also, you should include the NPI of the temporary doctor in box 23 on the CMS-1500 billing form.

But that's not all. There are other details you should keep in mind.

You can bill for a locum tenens for 60 continuous days. If the locum leaves your practice for a time and then comes back, the 60-day clock starts again. If a physician leaves your practice for good, you can still bill for a locum tenens as long as the doctor who left the practice is billing with a different tax ID at his new practice.

Keep Copies of the Locum's Claims

Medicare requires you to maintain a separate record of all the claims you submit for the locum tenens physician. There are a few ways to do this, experts say.

You can make an extra copy of each of the locum's claims and keep the copies in a separate paper file for the locum tenens, or you can use your computer system to track the locum tenens. The computer system at Einstein Healthcare Network in Philadelphia allows billing staff to look up the NPI listed in box 23 of the billing form, says surgical coding specialist Christine Endes. "This way, we can reference it at any time," she adds.

Alternatively, a search for claims billed with modifier Q6 will also turn up those claims submitted for services provided by a locum tenens.

New numbers: Endes and her colleagues also assigned different numbers internally to locum tenens physicians for tracking purposes. Normally, if staffers type in a physician's NPI, the computer will print out a bill under that doctor's name, but typing in a special number for the locum tenens produces a bill with the absent doctor's name and modifier Q6 attached -- and it adds the locum's UPIN to box 23.

Sift Through Similar Modifiers

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).

You use modifier Q5, for example, when your physician arranges with another doctor to cover each other's patients on weekends. In this situation, Doctor A will see Doctor B's patients and bill under Doctor B's NPI using modifier Q5. The physicians don't exchange any money because the services even out over time.

Stick With True Locums Situations

Many coders agree that people have trouble with locum tenens only when they try to use locum tenens billing for a few situations it wasn't designed for:

1. A newly hired physician who isn't credentialed yet. You can't bill for a locum tenens unless one of your regular physicians is really away.

2. A physician assistant or certified registered nurse anesthetist who is substituting for another PA or CRNA who is out of town. The locum tenens rules are only for doctors.

3. Using a locum tenens to supplement available providers for patient care while conducting a physician search for a new physician to add to the staff.

Caution: Stick to the 60-day timeframe, or you might find yourself with some denials.

"The '60 continuous days' is calendar days, not worked days, as many people try to interpret it," says Pam Marshall with Northern Colorado Professional Services in Fort Collins. "If a locum tenens worked off and on for 20 total days out of two months, you've still maxed the clock."

Check the timing: Keep track of the time the locum tenens is off before the "clock" starts again, Marshall adds, because payers might have guidelines regarding time spans. Noridian, for example, unofficially suggests waiting two to three months before using the same locum tenens again.

Watch for This Payer Pitfall

Locum tenens guidelines for commercial payers and state Medicaid programs can be very different.

"Several of our commercial payers don't recognize the Q6 and just want claims billed under the absent provider's information," Marshall says. "Some want the locum credentialed by the insurance carrier but don't want the claim billed under the locum's name."

Because of these differences, check with your payers periodically to verify that their guidelines for locum billing haven't changed.

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