Podiatry Coding & Billing Alert

Hint: Pay attention to the time limit.

Imagine this scenario: Dr. Smith, one of the podiatrists you work for, is diagnosed with breast cancer. She decides to take six weeks off while she goes through her first round of chemotherapy treatments. Dr. Smith chooses to bring in a locum tenens (LT) physician, Dr. Baker, to cover for her during her absence. Do you know how to code for this scenario?

Official definition: Locum tenens means “(one) holding a place” in Latin. In the medical field, you bring in an LT physician to temporarily replace another physician who cannot be in the office for some reason such as vacation, illness, or maternity leave.

Don’t fret:  Ask these three questions, so the guidelines for LT won’t trip you up.

Question 1: Can we bill LT for non-physicians?

Answer 1: No. Although many practices may try to use a locum for other employees, you can only use LT when substituting for a physician (medical doctor [MD], doctor of osteopathic medicine [DO]), or Doctor of Podiatric Medicine [DPM]).

“One of the biggest problems I see is when practices try to bring in a locum tenens for a nurse practitioner or a PA (physician assistant) who is going to be gone,” says Maggie M. Mac, CPC, CEMC, CHC, CMM, ICCE, AHIMA-approved ICD-10 CM/PCS trainer and president of Maggie Mac-Medical Practice Consulting in Clearwater, Florida. “A locum tenens can be used as a replacement for a physician — not for anyone else.”

Bottom line: Never use a LT in place of anyone other than a physician.

Question 2: How important is the time limit regarding LT?

Answer 2: The time limit concerning LT physicians is crucial, and CMS sets a strict 60-day stipulation for using an LT physician.

Usually, an LT can fill in for the same physician for no longer than 60 continuous days, starting with the first day of service. The 60 days can include weekends, but the locum cannot skip days in between, then continue after the 60 days.

Exception: According to section 116 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSE), enacted on December 29, 2007, “the exception to the 60-day limit on substitute physician billing for physicians called to active duty in the Armed Forces has been extended for services furnished from January 1, 2008 through June 30, 2008 … a physician called to active duty may bill for substitute physician services from January 1, 2008 through June 30, 2008 for longer than the 60-day limit.”

“With many physicians being called up for military medical work, this is always an important exception to keep in mind,” says Suzan Hauptman, CPC, CEMC, CEDC, senior principal of ACE Med group in Pittsburgh, Pennsylvania. She worked with a physician who was in Iraq for nine months and having the LT on board was valuable in keeping the schedule full and patient satisfaction up.

Question 3: Can we hire an LT as “extra help”?

Answer 3: No. An LT provider can absolutely not be “hired” by the practice, according to Melanie Witt, RN, CPC, MA, an independent coding expert based in Guadalupita, New Mexico.

“The locum tenens physician is not an employee, and the practice pays a fee to the agency that employees the locum to come to the practice,” Witt says. “It is treated as a contractual arrangement.”

Mac agrees, and points out that you cannot view locum tenens as “extra help” because in this situation, you must be temporarily replacing the physician. The original physician you are replacing cannot be seeing patients at the same time as the locum.

Remember: An LT physician usually has no practice of his own and moves from area to area as needed. The locum retains the status of an independent contractor, not an employee.