Locum Tenens Billing: How it Works
When your doctors take a well-deserved break, Medicare allows you to bring in a temporary replacement to keep your practice running smoothly. This temporary replacement is known as a locum tenens physician, and you can bill for their services using the physician identification number of the doctor they are covering.
The Basics of Locum Tenens Billing
Billing for locum tenens services is governed by a specific Medicare rule, which applies exclusively to Medicare and physician services. Verifying whether they follow this Medicare rule is crucial for other payers, such as Medicaid or commercial insurers. If not, you’ll need to understand their specific guidelines for reimbursing locum tenens services.
According to the Center for Medicare & Medicaid Services (CMS), a locum tenens physician can provide services to Medicare patients for a continuous period of up to 60 days. The only exception is if the regular physician is called to active duty in the Armed Forces.
Billing for Locum Tenens Engagements of Less Than 60 Days
Medicare’s rules specify that a locum tenens physician may work in your practice for only 60 consecutive days. If the regular physician returns briefly and then takes another leave, you can use the same locum tenens physician for a new 60-day period.
Medicare billing conditions:
- The regular physician is unavailable to provide the service.
- The Medicare beneficiary seeks or has arranged to receive services from the original physician.
- The substitute is paid on a per diem or fee-for-time basis.
- The substitute physician does not provide services to Medicare patients for more than 60 consecutive days.
It’s important to note that the 60-day period starts on the first day the locum tenens physician sees a patient, not when the regular physician first takes leave.
To properly bill for locum tenens services, include modifier Q6 on the claim form. This modifier indicates that the service was provided by a locum tenens physician under a fee-for-time compensation arrangement.
Billing for Locum Tenens Services Beyond 60 Days
If a locum tenens provider is needed for more than 60 days, there are options to ensure continuous coverage without violating Medicare rules:
- Enroll the locum tenens provider with your organization’s payer mix (Medicare, Medicaid, commercial payers) before their start date or as soon as possible. After the 60-day window, you would bill using the locum tenens provider’s National Provider Identifier (NPI) as if they were a permanent physician.
- Have the regular provider return to reset the 60-day clock and then resume using the locum tenens physician or engage a new locum tenens provider for an additional 60 days.
More Tips for Locum Tenens Billing
- Use the regular physician's NPI on the CMS-1500 claim form in block 24J, not the locum tenens physician’s NPI.
- Append modifier Q6 to CPT/HCPCS codes in box 24D to indicate services were provided by a locum tenens physician.
- Maintain detailed records of all services provided by the locum tenens physician, including their NPI. These records must be available for review upon request by the A/B MACs Part B.
By correctly understanding how to bill for locum tenens services, your facility can continue delivering high-quality care without interruption or loss of revenue. If you anticipate needing locum tenens services beyond 60 days, starting the payer enrollment process as soon as possible is advisable. Proper billing for locum tenens services ensures compliance with Medicare rules and helps maintain the financial health of your practice.
