Practice Management Alert

Remember: You can’t bill locum tenens for ‘extra help.’

Summer’s here, which means some of your physicians might be headed out on extended holidays or sabbaticals. When a physician takes an extended leave, the practice often hires a locum tenens physician to fill in.

Benefit: When you hire a locum tenens physician, you can bill for her services under the absent physician’s name and Medicare identification number, still bringing money in to your practice even though your physician is away. But if you aren’t careful, you could land your practice in hot water with denials and increased payer scrutiny. 

“Medicare has certain parameters that need to be met in order to bill locum tenens, and many other insurance companies adopt similar policies,” explains Laureen Jandroep, CPC, COC, CPC-I, CPPM, founder/CEO Certification Coaching Organization, LLC in Oceanville, N.J.

Dodge some of the speedbumps that might pop up when a physician takes leave by following these locum tenens tenets.

Rule 1: Locum Must Be Subbing For Another Physician

When you are billing for the locum, she must be filling in for another physician who has taken leave for some reason. You cannot hire temporary physicians as extra help and bill locum tenens, confirms Catherine Brink, BS, CMM, CPC, CMSCS, CPOM, president of Healthcare Resource Management Inc. in Spring Lake, NJ.

“The locum tenens physician must be substituting for a physician within the practice, and cannot [be] a contractual employee of the practice,” she adds.

So if Dr. A goes on vacation and you hire Dr. B to take over her case load, you might bill locum tenens for Dr. B’s services. If you hire Dr. B for two months to help out with back-to-school physicals, you cannot bill locum tenens.

Rule 2: Bill Locum’s Services Under Absent Physician’s ID

When billing for the locum tenens’s services, you must be sure to bill under the name and Medicare ID of the absent physician, advises Jandroep. Further, you should append modifier Q6 (Service furnished by a locum tenens physician) to any code you are billing for the locum tenens’s services.

A locum tenens claim must also include the practice group’s National Provider Identifier (NPI), and the NPI of the physician the locum is subbing for.

Example: Dr. A is on leave, and Dr. B is the locum. Dr. B performs a level-two E/M service for an established patient. On the claim, you should report 99212 (Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: a problem focused history; a problem focused examination; straightforward medical decision making…) for the service with modifier Q6 appended to show that you are billing for a locum. File the claim under Dr. A’s name and NPI. 

Rule 3: Observe 60-Day Limit For Locums

Locums can’t fill in forever. Medicare stipulates that a locum tenens physician can substitute for the same physician for 60 continuous days, starting with his first day of service, says Jandroep. Other payers that follow locum rules might have different time constraints, she continues.

“If coverage is needed for longer than 60 days, then the covering physician should be added to the group and their NPI number [should] be used instead of the regular physician’s,” explains Jandroep.

Rule 4: Keep Detailed Locum Records

When you are employing a locum tenens physician, you should “absolutely” keep a record of all the services the locum provides, Brink recommends.

Keeping this record is good practice “in case of an audit, and for compliance with Medicare billing and coding guidelines,” explains Brink.