Wiki Locum Tenens & Place of Service

[zavalag]

Hello,
I need guidance in regards to Locum Tenens billing. Here is the the scenario

1) Hospital Base Pathology Group
2) Services are rendered at ABC Hospital. They also have specimens from another hospital (123 Hospital) sent to ABC to be processed.
3) One Pathologist Leaves
4) A Locum Tenens was hired to perform the work for the provider who left however; only for the work that comes from the other hospital (123 Hospital)
5) The Locum does not have hospital privileges at ABC Hospital and that is why specimens were instead shipped to AAA Hospital to be processed.
(Note: The Locum has his personal business at AAA hospital, but does not want this temporary work to be mixed into his business.)

Question:
a) Is this Locum arrangement even valid?
b) Can we use the Pathologist who left add Q6 modifier and bill under AAA Hospital location since that is where it's being processed?

We have been told to use the ABC hospital location where the group is and Pathologist left from.. But I don't think this is right. The Locum is not there working at that facility.

I tried finding this on the CMS manuals, but unable to find specific verbiage to support why it shouldn't be done this way.

Thank you,
GZ

 

[thomas7331]

This is a rather unusual and convoluted situation that involves several different issues so I don't think you are going to find a source that gives you a definitive answer - this is really something a compliance expert would need to sit down and review carefully. CMS guidelines for both Locum billing and for correct use of the place of service for the professional component are notoriously lacking in specifics, and I'd note that using the incorrect hospital location, even if an error, would be informational only and not necessarily cause an incorrect payment. Hospitals frequently refer out pathology to other facilities when they are unable to process in-house, so that is not too concerning; and professional services of pathologists and radiologists are also routinely contracted to outside entities. The issue of privileges involves individual hospital policy more than CMS regulation. Another factor that could enter into this is whether the locum provider is billing just professional services or also involved with the technical component and how that is being billed. I personally would probably not be too concerned about this as long as the services provided are legitimate - it sounds to me like they taking these steps in order to be compliant rather than the other way around. But really, this is a complicated scenario and there are too many things to consider to be able to give you an easy answer. If you have concerns, my recommendation is that the best approach would be to take them to your organization's or the hospital's compliance officer so that they can do a thorough review and make sure it is a compliant arrangement.