Guide to Billing for Locum Tenens Services

It's a sunny Monday morning, and you're sipping your freshly brewed coffee while reviewing your medical practice's finances. A significant portion of your staffing expenses involves locum tenens professionals who have been instrumental in ensuring continuous care for your patients. Yet, as you examine the numbers, you can't help but wonder if you're navigating the billing process for these temporary medical professionals correctly.

You're not alone. Billing for locum tenens services can be challenging. Contracting temporary physicians and navigating the associated billing procedures can feel overwhelming for many medical practices and facilities. Without a solid understanding, you could leave money on the table or, even worse, face potential compliance issues.

Fortunately, with the proper information and understanding, you can ensure that your practice is compliant and financially optimized regarding locum tenens billing.

With that in mind, keep reading to arm yourself with the knowledge you need to manage this aspect of your practice. Whether you're new to the concept or simply looking for a refresher, this guide is tailored for you.

Learning The Basics About Locum Tenens Billing

Locum Tenens services come into play when practices need a temporary physician replacement due to various reasons such as:

• Illness
• Maternity leave
• Vacations
• Continuing education 

The billing process for such services can be tricky, especially given that different rules apply based on the payer. 

When dealing with Medicare, it's essential to recognize that the governing rules apply specifically to Medicare and physician services. Before billing other entities like Medicaid or commercial payers, it's vital to determine if they follow the Medicare rule. If not, you must familiarize yourself with their specific reimbursement rules.

According to the Center for Medicare and Medicaid Services (CMS), a locum tenens physician can attend to Medicare patients continuously, not exceeding 60 days. The only exception is if the regular physician has been called for armed forces active duty.

Related: What is Locum Tenens? 

Identifying Locum Tenens: What You Need to Know

One of the initial steps in the process is correctly identifying a locum tenens physician. This individual doesn't need to be registered in the Medicare program or share the same specialty as the regular physician. However, they should have a National Provider Identifier (NPI) and an unrestricted license in their practice state.

Remember, a locum tenens physician cannot be leveraged for business expansion or growth. Medicare beneficiaries must aim to get services from a regular physician. Assistance by the locum tenens should not span a continuous period of over 60 days, except for certain exceptions.

Liaising with your state's Medicaid office and commercial carriers about their locum tenens policies is also advisable. Some follow the CMS policy, while others have different enrollment requirements.

Are you looking for a locum tenen doctor but worry about the billing? Check out our services and see how we can help you recruit the best while staying compliant with billing.

Planned Duration for Less Than 60 Days

CMS has provided specific guidelines when a locum tenens need is under 60 days. They allow the regular physician or physical therapist to obtain the Part B payment for services provided by the substitute, given certain conditions are met. These conditions include:

• The unavailability of the regular physician
• Arrangement or intent of the Medicare beneficiary to get services from a regular physician
• Payment to the substitute on a per diem or similar basis
• The replacement will not treat Medicare patients for more than 60 continuous days. 

An exception to this is when the regular physician is on armed forces active duty. The 60-day period starts when the locum tenens physician first attends to a patient, not when the regular physician begins their absence. 

Planned Duration of More Than 60 Days

In medical practice, there are instances when the requirement for a locum tenens provider surpasses the 60 days set by Medicare. 

When such situations occur, practices are typically presented with two viable options:

Start With The Contracted Payers

When acquiring a locum tenens provider, initiate enrollment with the organization's contracted payers. This includes Medicare, Medicaid, and other commercial payers. 

This should ideally be done before the locum tenens provider's commencement date or as swiftly as possible once they begin. After the 60-day Medicare limit, you can then bill under the doctor’s NPI number, treating them like a permanent physician.

Reintroduce Absent Physician

Another approach is to reintroduce the absent physician back to the practice momentarily. Doing so resets the 60-day limit. This enables you to engage the same locum tenens physician again or opt for a new doctor for 60 days. 

Related: Locum Tenens Physician Salary

Can New Physicians Be Billed as Substitutes during Credentialing?

Billing a newly incorporated physician as a substitute isn't appropriate if they've been employed as a permanent fixture of the practice. The credentialing procedure for a new physician should commence around 60 days before their designated start date. 

Let's say you have a new physician stepping in for the one who has exited the group. In that case, they can be billed as a substitute for the initial 60 days, based on the guidelines mentioned above. 

In such scenarios, it's recommended to compensate the incoming physician as an independent contractor rather than a salaried team member to ensure harmony with CMS norms.

Avoid Common Misunderstandings

Some locum tenens placement firms might inadvertently offer misguided advice. This causes misconceptions about the longevity of these temporary positions. Not only that, they might bill NPs and PAs the same way as physicians, which will cause many issues.

For example, when it comes to the "physician for physician services," it entails that non-physician practitioners such as nurse practitioners or physician assistants cannot be billed under the locum tenens rule. 

As of June 23, 2017, CMS revamped its locum tenens directive, expanding its scope to include physical therapists. To encapsulate both categories, the term "locum tenens" has been substituted with "fee-for-time." 

Modifiers Q5 and Q6 remain in use and have also been extended to physical therapists. Additionally, when a physician or therapist is summoned for active military duty for over 60 days, the reciprocal or fee-for-time arrangement is applicable for the entire duration.

Need more guidance on billing properly for locum tenens? Schedule an appointment today to talk to our experts

What You Need to Know About Fee-For-Time Model?

The fee-for-time compensation model strictly pertains to physician replacements and does not apply to non-physician providers like nurse practitioners, physician assistants, or radiology assistants. 

For transparency and to ensure compliance during potential Medicare audits, it's crucial for the agreement with the substitute physician to be documented in writing. Moreover, it aids in eliminating any ambiguities between the practice and the locum tenens.

How Does This Affect Commercial Payers?

Contrary to popular belief, commercial payers don't necessarily mirror Medicare's stance on substitute physicians. Medical groups must liaise directly with their contracted payers. 

Some might necessitate a brief credentialing process before acknowledging modifier Q6. If the locum tenens engagement is likely to surpass 60 days, initiating the credentialing process with pivotal payers at the earliest is advisable.

How Daily Care Solutions Streamlines Billing

Navigating the complexities of locum tenens billing can be a daunting task for many practices. At Daily Care Solutions, we specialize in streamlining this process. Our team of experts stays updated with the latest regulations and ensures that you remain compliant while maximizing your reimbursements. 

Whether you're dealing with Medicare, Medicaid, or commercial payers, we can help. Let us handle the intricacies of billing so you can focus on providing top-notch patient care.

Final Thoughts on Billing for Locum Tenens Services

Navigating the complexities of billing for locum tenens services can be challenging, but understanding the ins and outs is crucial for healthcare facilities and practitioners alike. Locum tenens, or temporary medical staff, offer invaluable support to healthcare institutions, ensuring that patient care is never compromised due to staff shortages or other unforeseen circumstances. 

Correctly billing these services ensures institutions comply with regulations, avoiding potential pitfalls and penalties.

With the evolving healthcare industry landscape, remaining ahead of the billing game is essential. This promotes transparency and fortifies trust between locum tenens, healthcare facilities, and patients. When done correctly, billing for locum tenens services becomes a seamless part of the broader medical operations, allowing administrators and healthcare professionals to focus on what truly matters: delivering high-quality patient care.

Taking on the task of billing for locum tenens services in-house can be daunting, especially with the intricacies involved in ensuring accuracy and compliance. Therefore, seeking expert assistance or consultation in this domain can be immensely beneficial. After all, an error in billing could lead to financial setbacks or regulatory complications.

If you're on the journey of building or expanding your locum tenens team, ensure you're equipped with the knowledge and tools to manage the billing aspect efficiently. Don't let the billing process intimidate you. With the proper guidance, it becomes an integral yet manageable aspect of the broader healthcare service you offer.

For further insights, guidance, or assistance in building your locum tenens dream team, we can help. Contact us today and discover how we can work together to serve your patients better.