While you search for the right physician to join your practice or add to your hospital roster, your patients still need care. To provide uninterrupted care to your patients and to maintain a revenue stream, you might choose to fill this gap with a locum tenens physician. Learn more about what exactly a locum tenens is, as well as what is and is not an acceptable use of one.
What Is a Locum Tenens?
“Locum tenens” is the phrase historically used by the Centers for Medicare and Medicaid Services to describe what is now referred to as a fee-for-time compensation arrangement. In a locum tenens situation, a substitute physician or physical therapist provides services in place of the regular physician, and the regular physician is able to bill Medicare for those services provided to Medicare Part B beneficiaries.
What Rules Must Be Followed?
For Medicare eligibility and reimbursement, specific criteria must be met for a legitimate locum tenens, or fee-for-time compensation arrangement:
- The substitute provider can only bill under the regular provider’s National Provider Identifier, or NPI, number for 60 continuous calendar days, unless the regular physician was called to active military duty.
- The patients must seek the services of the regular physician.
- Claims submitted to Medicare must use the modifier “Q5” or “Q6,” as appropriate, to indicate the use of a locum tenens.
- The substitute physician must not be an employee, but an independent contractor.
- The substitute physician must be paid on a per diem or similar time basis.
What Are Acceptable Uses of a Locum Tenens?
Examples of acceptable uses for a fee-for-time compensation arrangement include the following scenarios:
- A physician takes a four-week vacation. During that time, a physician from a staffing agency sees that physician’s patients. Those visits can be billed to Medicare under the regular physician’s name, and Medicare will reimburse the regular physician as if she performed the services.
- A pediatrician leaves the medical group. While the group tries to recruit a replacement, a substitute physician covers that pediatrician’s caseload for up to 60 days.
- Two locum tenens providers cover the panel of a physician on leave for 60 days, alternating the weeks they work.
What Are Unacceptable Uses of a Locum Tenens?
For Medicare purposes, the following are unacceptable uses of a fee-for-time compensation arrangement:
- If a physician dies, no one can bill under that physician’s name.
- Locum tenens arrangements for Medicare do not include nurse practitioners, physician assistants or any other provider type besides physician and physical therapist (in certain geographies or region). However, they do not need to be of the same specialty.
- A newly hired physician cannot bill as a locum tenens provider while pending Medicare enrollment; employees do not qualify.
- You are expanding your practice and need additional providers. A fee-for-time arrangement would not qualify, since there is no regular physician to substitute for.
- The regular physician cannot provide services elsewhere while a substitute physician also is billing under her credentials; the regular physician cannot be available to work.
Note that the above rules apply to the Medicare program. Different insurance plans can have their own rules regarding the allowed use of a substitute physician.
Looking for a permanent hire? Contact Adaptive Medical Partners to let us help you find the right provider to join your practice for the long term.
