Practice Management Alert

Accurately collect for these fill-in providers, previously called locum tenens.

With the holiday season approaching, it’s likely that your providers will be taking time away from the practice. If you’re planning on using fill-in providers, you’ll need to update your billing processes in line with the fee-for-time (FFT) rules.

Previously referred to as locum tenens, FFT billing allows you to collect for the services of providers who are temporarily taking the place of your clinicians. Consider these five tips as you begin reporting FFT providers’ services.

Tip 1: FFT Billing Applies to Temporary Doctors

In most cases, you can collect fee-for-time compensation in situations when a substitute physician provides services in place of the regular physician because the regular doctor isn’t available.

CMS’ words: “The A/B MAC [Medicare Administrative Contractor] Part B may pay the patient’s regular physician for physicians’ services and services furnished incident to such services that are provided by a substitute physician during the absence of the regular physician where the regular physician pays the substitute on a per diem or similar fee-for-time basis, and certain other requirements are met,” the Centers for Medicare & Medicaid Services (CMS) says in Chapter 1 of the Medicare Carrier’s Manual.

Note that CMS specifically refers to “physicians” in this descriptor. While some practices try to use fee-for-time billing even when employing fill-in nurse practitioners (NPs) or physician assistants (PAs), that’s inappropriate. According to Part B MAC Noridian Medicare, “Services of non-physician practitioners (e.g., CRNAs, NPs and PAs) may not be billed under fee-for-time compensation arrangements or reciprocal billing reassignment exceptions … A regular physician is defined in this case as MDs or DOs.”

Physical therapist caveat: The only exception to the physician-only rule is that physical therapists (PTs) in a health professional shortage area (HPSA), a medically underserved area (MUA), or in a rural area may be able to bill using fee-for-time.

Tip 2: Use Modifier Q6

If you’re using an FFT billing arrangement, you must append modifier Q6 (Service furnished by a locum tenens physician) to all of the temporary doctor’s claims.

Some practices will bill the fill-in physician’s services under the existing doctor’s national provider identifier NPI and just leave off the Q6 modifier, acting as if the other doctor personally performed the service.

Although some practices may try to slip under the radar this way, eventually the MAC will discover the discrepancy, so should simply follow the rules and always use modifier Q6 on your claims.

Tip 3: Use the Regular Doctor’s NPI

When you’re billing using fee-for-time, you can’t use the fill-in physician’s NPI for your claims. Instead, you’ll report the fill-in doctor’s services under the NPI of the physician the fill-in is replacing, with modifier Q6 appended to the codes.

Many MACs require you to also include the NPI of the temporary doctor in box 23 on the CMS-1500 billing form. Check with your payers to confirm whether this is how you should submit your FFT claims before submitting them.

Tip 4: Mind the 60-Day Limit

Having a new physician as a fill-in at your practice doesn’t allow you unlimited time reporting services using modifier Q6. In reality, if you’re using fee-for-time billing, you’re under a strict timeline of 60 continuous days. In rare cases when a physician is on active duty in the armed forces, Medicare may allow you to bill FFT services beyond the 60-day limit.

If you need coverage 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.

Tip 5: Avoid Common FFT Compliance Issues

Payers are always watching for common FFT issues, so it’s important to know some of the most frequent errors in FFT billing.

Using FFT for noncredentialled providers: Some practices get tired of waiting for a new physician’s Medicare credentialing application to process, so they report the new doctor’s services under an existing physician’s ID number with modifier Q6 appended. However, this is not appropriate. In reality, FFT is designed to represent services performed in the absence of the regular physician, not as a temporary stopgap for new providers.

In fact, the OIG addressed this issue by offering the following example of “misrepresentation of services to the Federal health care programs” in the Oct. 5, 2000, Federal Register: “When the practice bills for a service performed by Dr. B, who has not yet been issued a Medicare provider number, using Dr. A’s Medicare provider number. Physician practices need to bill using the correct Medicare provider number, even if that means delaying billing until the physician receives his/her provider number.”

Using FFT for “extra help”: If you’re hiring a physician on a temporary basis to assist during high-volume periods, you can’t use FFT billing to report the physician’s services. The fill-in doctors are not holding the place of the regular doctor, and therefore, fee-for-time billing doesn’t apply.

Using FFT for services normally included in global period: Some practices think there’s a loophole in the FFT process, allowing them to report services that would normally be included in a global period separately if an FFT doctor performs them. However, this is inaccurate. “If postoperative services are furnished by the substitute physician, the services cannot be billed with modifier Q6 since the regular physician is paid a global fee,” Noridian says.

Torrey Kim, Contributing Writer, Raleigh, North Carolina