It’s Vacation Time. Does Your Anesthesia Group Have the Right Coverage Using Locum Tenens?
It’s summertime and vacation plans are high on everyone’s list. Sometimes arranging coverage is difficult and groups resort to using locum tenens. Somewhat surprisingly, a recent survey by physician staffing firm LocumTenens.com revealed that 16 percent of the respondents who hire locum tenens physicians do not bill for their services, because they do not know how or because the exercise seems too complicated. Medicare and most commercial payers allow payment for the use of locum tenens providers, however, and it is worth knowing the rules.
Vacations are clearly appropriate for the use of locum tenens as long as the practice follows the applicable guidelines when filling the gaps. It’s more than just determining who is working for whom; there are certain billing requirements depending on which carrier the claim goes to. Don’t get stuck providing services and paying a locum tenens for cases that aren’t billed.
According to Medicare’s locum tenens payment policy, physicians may “retain substitute physicians to take over their professional practices when the regular physicians are absent for reasons such as illness, pregnancy, vacation, or continuing medical education, and for the regular physician to bill and receive payment for the substitute physician’s services as though he/she performed them.” 1
Locum tenens should be used for a short period of time, no more than 60 continuous days. As long as the regular physician returns for as little as a day at the end of the 60 days, a new 60-day period may begin. Use caution when engaging a locum tenens for long periods of time. If the 60-day limit is exceeded, the physician who is replacing the regular physician should be properly credentialed and enrolled. There may be extensions available in the event of a military leave if a physician has been called to active duty or reserves in the Armed Forces.
A locum tenens should not be considered an employee of the practice, but rather an independent contractor, part-time or per diem.
When billing for the services of a locum tenens to Medicare, you should report the regular physician’s name and NPI on the claim and append a HCPCS Q6 modifier after the procedure code. The Q6 modifier indicates that a substitute physician performed the service. In the event of an audit, each practice must have a record of who actually provided the services. Payment is made to the regular physician in the same manner as if he or she performed the services. Medicare does not reduce payment in these instances and the locum tenens does not have to be enrolled with Medicare, unless the 60-day limit is exceeded.
What about other payers? Most state Medicaid plans follow the Medicare guidelines. Check with your own state’s Medicaid plan. If your Medicaid carrier does not allow billing under the regular physician’s identification, you will need to follow the normal enrollment procedures as you would if this were a new physician.
Typically, commercial payers will also allow billing for a locum tenens under the regular physician’s name and NPI. Some payers will want to credential the locum physician prior to paying a claim for his or her services and will require you to bill under the locum’s name, e.g., Regence Blue Shield of Washington.2 If the payer has delegated credentialing to you, the timeline for this can be quite short. If you must rely on the insurance company, allow 30–60 days for their credentialing process. While many carriers will pay retroactively to the first date of service, some will only pay claims with dates of service after the finalization of the credentialing process. Check your contract for the applicable requirements. If you are not contracted with the carrier, credentialing is usually not required and the carrier will pay for the locum’s services when billed under the regular physician’s NPI our local carrier rules related to locum tenens before engaging their services.
Another area to monitor is the actual daily schedule. Make certain that you don’t have more locum tenens physicians working than you have regular physicians for them to cover. A locum tenens can’t provide services on the same calendar day as the regular physician he or she is covering. For example, Dr. A, a regular physician, works 0700-1500 and leaves for vacation immediately following his shift. Dr. B, a locum tenens, gets called to work at 2100 that same day. Unless there is another vacationing physician off the schedule that day for the locum tenens to be billed under, any service Dr. B performs that same calendar day is not billable. Dr. B’s services can be billed beginning 12:01 am the next calendar day under Dr. A. Your billing office may ask for a copy of the schedule to keep on file.
Finally, a CRNA is never considered a locum tenens for an absent physician, or even for another CRNA. CRNAs may fill in the schedule as your state and carriers allow, but CRNAs need to be enrolled with each carrier and billed under their own name and NPI. Make certain your billing service is notified in advance when a CRNA is filling in for your practice. This will allow time for credentialing and enrollment with your group’s carriers.
Advance schedule planning and solid arrangements with locum tenens physicians can help ensure that all group members are able to take their much needed vacation and that revenues won’t decline during their absence.