Practice Management Alert

Question: What’s a good resource that gives some kind of answer as to how long you can use “Locum services” under a provider of a practice? I know each locum can only do 60 days (per most payer guidelines), but how many different locums can you have work under the one physician’s information?

AAPC Forum Participant

Answer: The Centers for Medicare & Medicaid Services (CMS) has modified the locum services limit while the public health emergency (PHE) continues.

On page 35 of the COVID-19 Emergency Declaration of Blanket Waivers for Health Care Providers, CMS says:

“CMS is modifying the 60-day limit in section 1842(b)(6) (D)(iii) of the Social Security Act to allow a physician or physical therapist to use the same substitute for the entire time he or she is unavailable to provide services during the COVID-19 emergency plus an additional period of no more than 60 continuous days after the public health emergency expires. On the 61st day after the public health emergency ends (or earlier if desired), the regular physician or physical therapist must use a different substitute or return to work in his or her practice for at least one day in order to reset the 60-day clock. Without this flexibility, the regular physician or physical therapist generally could not use a single substitute for a continuous period of longer than 60 days and would instead be required to secure a series of substitutes to cover sequential 60-day periods. The modified timetable applies to both types of substitute billing arrangements under Medicare fee-for-service (i.e., reciprocal billing arrangements and fee-for-time compensation arrangements (formerly known as locum tenens)).

Effective Jan. 16, Secretary of Health and Human Services Xavier Becerra renewed the PHE for the eighth time.

Read more about locum services during the pandemic here,http://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf.

CMS does not mention anything about total time period restrictions during or before the PHE.