Are These Locum Tenens Myths Clouding Your Compliance?
Published on Fri Aug 18, 2006
Obeying the 60-day limit may be trickier than you think
You may have some dangerous misconceptions about how to properly distinguish locum tenens from reciprocal billing--and about the 60-day time frame that applies to both cases.
To be sure you are appending modifiers Q5 (Service furnished by a substitute physician under a reciprocal billing arrangement) and Q6 (Service furnished by a locum tenens physician) only when appropriate, read on to discover the truths behind these four common myths: Myth #1: A locum tenens or reciprocal billing physician must provide services consecutively for 60 days in order to time out--and the clock restarts every time there is a break in service. "If you utilize the service of a substitute doctor and bill under the absent physician's numbers, you have a 60-day clock that starts on the first day of service," says Robert B. Burleigh, CHBME, president of Brandywine Healthcare Services in West Chester, Pa. And whether the locum tenens or reciprocal billing pediatrician provides services "every day for 60 days, or once a week for 60 days--at the end of 60 days, the clock stops."
Don't play games: Some practices will bill a substitute pediatrician's services with Q5 or Q6 for many months or even years using the rationale that the substitute physician worked only once in a while, thereby resetting the clock every time there was a period without services rendered. This is noncompliant billing, Burleigh says.
A simple example should help you understand, says Mary Falbo, MBA, CPC, president of Millennium Healthcare Consulting in Lansdale, Pa. She points to the following example based on Medicare policy that private payers may follow:
Suppose your office has a substitute physician provide services to your pediatrician's patients on July 2 and various dates thereafter, including Aug. 30 and Sept. 2. This means your substitute had a 63-day period of continuous services.
Your doctor may not bill for the Sept. 2 services because they occurred after the 60-day period had finished. Instead, the substitute physician must bill for these services in his own name.
Good reason: 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, Burleigh says. 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 because a locum tenens arrangement is a great way for a Medicare-excluded provider to hide behind your physician's number, Burleigh says.
No exceptions: You may be tempted to continue reporting a substitute physician's services as locum tenens or reciprocal billing if she regularly fills in at your practice, but always [...]
