Radiology Coding Alert

Bill Locum Tenens With -Q6 Modifier

Summertime means sunshine, lounging by the pool, cookouts -- and vacations for coders and radiologists.

Vacation season or not, patients still need radiology services, and your practice may hire a temporary radiologist to cover staff shortages. In this case, professional coders must be aware of the rules that govern locum tenens physicians, as well as the reporting procedures required by both Medicare and private payers. Locum tenens means "one holding the place of & " in Latin and describes physicians contracted to provide services on either a short-term or long-term basis. Locum tenens physicians may be used as temporary replacements for a number of reasons, including vacations, maternity leaves, illnesses or accidents, or continuing education. Coding and billing their services depends on many factors, including how long they serve the practice and whether they are substituting for another radiologist or augmenting his services.

 "Often, practices hire locum tenens radiologists and are able to bill Medicare for their services simply using the regular radiologist's name and provider number," explains Sandee Valdez, radiology operations manager for CompHealth, one of the largest locum tenens firms in the country, located in Salt Lake City. "However, practices must be aware that when doing so, they must append each procedure code reported with the -Q6 modifier (service furnished by a locum tenens physician). This lets Medicare know that the claim should be processed under the regular physician's name, but that the work was actually performed by a locum tenens physician."
 
Two Rules Guide Use of -Q6
 
Two conditions govern use of this modifier, she adds. First, the locum tenens physician must be substituting for a permanent radiologist who is temporarily away from the practice. Second, coverage cannot exceed 60 consecutive days to qualify as locum tenens service reported with the -Q6 modifier. 

If neither of these conditions is met, Radiology Practices must obtain a provider identification number (PIN) for the locum tenens physician through their local Medicare carrier. "For instance, if you are expanding your practice and are using a locum tenens physician while recruiting a new staff member, you would not be able to bill those services under the regular radiologist's PIN with the -Q6," Valdez says. "You would need to apply for a separate PIN for the locum tenens physician."

She advises practices not to delay when they anticipate contracting with a locum tenens physician whose services don't conform to the -Q6 requirements. "It can take some time to receive the PIN and you won't be able to bill for the physician's services until you get it."

And, if the tenure of a short-term substitute is extended beyond 60 days, the practice needs to enroll the locum tenens radiologist with the carrier. One exception to this occurs if the temporary physician worked for less than 60 days, but is called back for another assignment at a later date, says Kathy Pride, CPC, CCS-P, coding specialist for Martin Memorial Medical Group, a practice with 57 primary care physicians in Stuart, Fla. "The 60-day rule applies to continuous days," she explains. "Perhaps you use a locum tenens physician to cover for a radiologist during a lengthy illness. The radiologist returns to work after 45 days, but then suffers a relapse two weeks later. You may call the original locum tenens physician back in and the 60-day cycle begins again."

Valdez notes, however, that practices cannot use this exception to continue contracting falsely with a locum tenens physician for a longer term. Medicare will investigate if it discovers that a practice repeatedly uses a specific substitute for slightly less than the 60 days, releases that individual for a short time, and then brings him or her back. This would be considered inappropriate use of -Q6.

Other public programs like Medicaid often have disparate rules and guidelines governing locum tenens. Also, commercial payers may or may not recognize the locum tenens at all, and some actually consider it a false claim to file in the name of a physician who did not render the service. Radiology Practices should check with all insurers when they anticipate hiring a substitute physician.
 
Don't Confuse -Q6 with -Q5
 
Pride notes that the -Q6 modifier should not be confused with the -Q5 modifier (service furnished by a substitute physician under a reciprocal billing arrangement). "The -Q5 modifier is typically used when one physician covers for another. For example, physician A and physician B are both in solo practice. They work out an arrangement that they alternate weekends covering for each other. Physician B may see physician A's patient one weekend, but would not bill for the service. Physician A would bill for the service, but append modifier -Q5 to let Medicare know that the work was actually performed by the other physician." She adds that no cash would be exchanged between the physicians. The reciprocal nature of their arrangement assumes that the services each provided the other's patients balance in the long run.