Podiatry Coding & Billing Alert

Question: One of the podiatrists in our practice will be traveling for two months and has made locum tenens arrangements with another surgeon to cover while he is away. My question is, the traveling surgeon works with a nurse practitioner who bills incident-to under his NPI — how should we bill the NP’s incident-to service while he is away?

Pennsylvania Subscriber

Answer: You may be able to continue to bill incident to using the traveling physician’s National Provider Identifier (NPI)

The supervising physician doesn’t have to be the physician associated with a patient’s care plan. Any physician can supervise, as long as the nurse practitioner (NP) is acting as an extension of the plan created by a physician.

Caution: You should verify any MD/NP collaboration agreement as well as the State Board of Nursing regulations for your state 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. A’s plan. Dr. B is the locum tenens physician during Dr. A’s absence. File the claim with Dr. A’s name and NPI, and append modifier Q6 (Service furnished by a locum tenens physician) to indicate a locum tenens physician was present instead of Dr. A.

Pitfall: CMS has a 60-day time limit for using locum tenens physicians. Because you stated that your surgeon will be gone longer than that, an alternate option would be necessary after the 60-day mark.

Resources: 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.”