Maximizing Insurance Billing For Locum Tenens Physical Therapy Services

Locum tenens is a Latin term that means placeholder or one holding a place. It refers to an arrangement where eligible healthcare providers can use a modifier to indicate that a replacement practitioner provided services to their patients on a particular day and can still receive full compensation for those services. This is particularly relevant for physical therapists (PTs) who can now take advantage of what was previously known as locum tenens.

The Centers for Medicare & Medicaid Services (CMS) allows payment for services provided by locum tenens physicians, but certain guidelines must be followed. The locum tenens physician does not need to be enrolled in Medicare or be in the same specialty as the physician they are filling in for, but they must have a National Provider Identifier (NPI) and an unrestricted license to practice in the state.

There are two types of locum tenens services: replacement and supplemental. Replacement locum tenens fill in for a regular physician's absence, typically for 60 days or less. Supplemental services are used when a practice needs to grow or replace a provider for more than 60 days.

For billing purposes, it is important to identify whether the locum tenens arrangement is for replacement or supplemental services. The regular physician or physical therapist is typically reimbursed for the locum tenens services, and certain modifiers (Q5 or Q6) are used to indicate that a replacement practitioner provided the services.

To ensure proper billing and reimbursement, it is crucial to understand the guidelines and requirements for locum tenens billing, especially when dealing with Medicare, Medicaid, and commercial payers.

Locum tenens billing for replacement services

Locum tenens is a Latin term that roughly translates to "placeholder". In the medical field, locum tenens refers to contracted physicians who fill in for a physician who has left the practice or is temporarily unavailable. Locum tenens physicians can help to ensure patients continue to receive top-quality care and that revenue isn't lost due to a vacancy.

Replacement vs Supplemental Services

The first step in billing for locum tenens services is to identify the type of temporary physician services you need: replacement or supplemental. Replacement services are used when your regular physician is unavailable to provide services, typically for 60 days or less. Supplemental services are used when you are looking to grow your practice and need a physician in addition to your current staff.

Billing for Replacement Services

Section 30.2.11 of the Medicare manual covers billing for replacement services. It allows a practice to bill for temporary physician services during the absence of a regular physician who normally would have been scheduled to see a patient. The regular physician must arrange coverage for no longer than 60 continuous days and then enter HCPCS code modifier Q6 after the procedure code during the billing process.

The regular physician or physical therapist is unavailable to provide the service. The regular physician or therapist pays the substitute for their services on a per diem or similar fee-for-time basis. The substitute physician or therapist does not provide services to Medicare patients over a continuous period of more than 60 days. The only exception is when the regular physician is called for active duty in the Armed Forces.

Claims must contain the NPI of the regular physician and not the locum or substitute physician. CPT/HCPCS codes must have the modifier Q6 appended as this would indicate that the billed services were furnished by the locum or substitute physician. A record of each service provided by the substitute physician or therapist must be kept on file along with their NPI. This record must be made available to the A/B MACs Part B upon request.

Locum tenens billing for supplemental services

Locum tenens is a Latin term that means "placeholder". Locum tenens physicians are contracted to substitute for a physician who has left the practice or is temporarily unavailable.

Supplemental services are used when you are looking to grow your practice and need the services of a physician in addition to your current staff or need to replace a provider for more than 60 days.

Section 30.2.7 of the Medicare manual covers billing for supplemental physician services. It allows a carrier to make payments to your group for services performed by a supplemental physician who has a contractual agreement to see your patients. There are two safeguard requirements that must be met before a claim can be paid in this type of arrangement:

• The entity receiving payment and the person that furnished the service are jointly and severally responsible for any Medicare overpayment to that entity.
• The person furnishing the service has unrestricted access to claims submitted by an entity for services provided by that person.

When using services performed under a contractual arrangement, the supplemental provider will complete the necessary applications to bill for services with each of your private carriers and the Medicaid program for your state. Additionally, the provider will complete Medicare’s Form 855R to allow your practice to bill Medicare for their services.

A provider may have billing rights assigned to multiple practices or groups, and the same form is used to rescind billing privileges once an assignment is completed.

Billing for Replacement Physician Services

Section 30.2.11 of the Medicare manual covers billing for replacement services. It allows a practice to bill for temporary physician services during the absence of a regular physician who normally would have been scheduled to see a patient.

For this type of reimbursement to take place, the regular physician arranges coverage for no longer than 60 continuous days and then enters HCPCS code modifier Q6 after the procedure code during the billing process.

Other Things to Note

• Many private payors and state Medicaid programs follow Medicare guidelines, but it’s good practice to verify each program independently.
• Although it may not make sense to enrol every locum tenens provider with every payor you work with, in many cases, you will want to enrol them with three to five of your largest payors.
• Locum tenens physicians may not bill Medicare; they should be paid on a per diem or similar fee-for-time basis.

Locum tenens billing for Medicare beneficiaries

Locum tenens is a Latin term that means "placeholder". In the medical field, a locum tenens physician is a contracted physician who substitutes for another physician who has left the practice or is temporarily unavailable.

The Centers for Medicare and Medicaid Services (CMS) allows payment for services provided by locum tenens physicians, but there are specific guidelines that must be followed for Medicare beneficiaries. Here are the key points to remember for locum tenens billing for Medicare beneficiaries:

Identifying Locum Tenens:

The locum tenens physician does not need to be enrolled in the Medicare program and does not have to be in the same specialty as the physician they are filling in for. However, they must have a National Provider Identifier (NPI) and an unrestricted license to practice in the state. Locum tenens physicians cannot be used to cover expansion or growth in a practice.

Billing Requirements:

• The regular physician or physical therapist must be unavailable to provide the service.
• The Medicare beneficiary must have arranged or sought to receive services from the regular physician or physical therapist.
• The regular physician or physical therapist must pay the locum tenens on a per diem or similar fee-for-time basis.
• Services provided by the locum tenens physician must not exceed a continuous period of 60 days. The only exception is if the regular physician is called for active duty in the Armed Forces.
• The Q6 modifier (service furnished under a fee-for-time compensation arrangement) must be appended after the CPT code on the CMS-1500 claim.
• Claims payment is made under the name and billing number of the regular physician or the practice that hired the locum tenens.
• A record of each service provided by the locum tenens physician, along with their NPI or Unique Provider Identification Number (UPIN), must be kept on file and made available to the A/B MACs Part B upon request.
• Do not bill for services provided by the locum tenens while waiting for the regular physician to be credentialed with Medicare.
• For supplemental services (i.e., when needing a physician in addition to the current staff or for replacement for more than 60 days), the locum tenens physician will need to be enrolled with the organisation's contracted payer mix (Medicare, Medicaid, commercial payers, etc.).

Common Misunderstandings:

The locum tenens provision is widely used but often misunderstood, which can put practices at risk if guidelines are not followed correctly. It is important to note that this provision is for "physician for physician services" only and does not include non-physician practitioners such as nurse practitioners and physician assistants.

Updates:

Effective June 23, 2017, CMS changed its locum tenens policy to include physical therapists. The term locum tenens has been replaced with "fee-for-time" to cover both arrangements under one policy. Modifiers Q5 and Q6 continue to be used and are applicable to physical therapists as well.

In summary, locum tenens billing for Medicare beneficiaries requires adherence to specific guidelines set by CMS. By following these guidelines, healthcare facilities can ensure proper reimbursement for temporary physician or physical therapist services while maintaining uninterrupted patient care.

Locum tenens billing for non-Medicare beneficiaries

Locum tenens is a Latin term that means "placeholder". It refers to an arrangement where eligible healthcare providers can use a modifier to indicate that a replacement practitioner provided services to their patients on a particular day and can still receive full compensation for those services.

• Have another therapist (who is credentialed) present during their service
• At the very least, make sure to co-sign all the notes

However, in order to co-sign a note, the credentialed therapist must provide direct on-site supervision. So, in essence, you would bill for the services provided by a non-credentialed substitute the same way you would for a PTA.

General billing guidelines for locum tenens

• The regular physician or physical therapist is unavailable to provide the service
• The Medicare beneficiary has arranged or seeks to receive the services from the regular physician or physical therapist
• The regular physician or physical therapist pays the substitute for his/her services on a per diem or similar fee-for-time basis
• The substitute physician or physical therapist does not provide the services to Medicare patients over a continuous period of longer than 60 days. The only exception is when the regular physician is called for active duty in the Armed forces
• The 60-day count would start on the first day the locum tenens physician sees a patient and not when the regular physician took their absence
• Q6 Modifier (service furnished under a fee-for-time compensation arrangement by a substitute physician or by a substitute physical therapist furnishing outpatient physical therapy services in a health professional shortage area, a medically underserved area, or a rural area) is appended after the CPT code
• Claims must contain the NPI of the regular physician and not the locum or substitute physician. This is entered in CMS-1500 claim in block 24J
• CPT/HCPCS codes must have the modifier Q6 appended as this would indicate that the billed services were furnished by the locum or substitute physician. This is added in box 24D
• A record of each service provided by the substitute physician or physical therapist must be kept on file along with the substitute physician’s or physical therapist’s NPI. This record must be made available to the A/B MACs Part B upon request

Locum tenens billing for Medicaid

Locum tenens is a Latin phrase that means “(one) holding a place.” In the medical field, locum tenens are contracted physicians who substitute for a physician who has left the practice or is temporarily unavailable. The Centers for Medicare & Medicaid Services (CMS) allows payment for services provided by locum tenens physicians, but specific guidelines must be followed.

Understanding Locum Tenens Billing

The locum tenens physician does not need to be enrolled in the Medicare program or be in the same specialty as the physician they are filling in for. However, they must have a National Provider Identifier (NPI) and an unrestricted license to practice in the state. It is important to note that locum tenens cannot be used to cover expansion or growth in a practice. Medicare beneficiaries must seek to receive services from the regular physician, and services may not be provided by the interim provider for more than 60 consecutive days.

Billing Procedures for Locum Tenens

Locum tenens physicians cannot bill Medicare directly; they should be paid on a per diem or similar fee-for-time basis. Claims payment is made under the name and billing number of the physician or the practice that hired the locum tenens physician. If the physician has left the practice, each claim must still have a rendering provider, so the practice would use their name and NPI with modifier Q6 to indicate that the service was furnished by a locum tenens physician.

Medicaid and Private Payer Enrollment

When billing for locum tenens services, it is essential to understand the reimbursement rules of Medicaid and private payers. While many private payers and state Medicaid programs follow Medicare guidelines, it is good practice to verify each program's policies independently. In most cases, you will want to enroll your locum tenens physicians with your major payers to ensure you can bill for the services they provide. This typically involves completing the standard Medicaid and private payer enrollment process required by your state and insurance carrier.

Understanding the 60-Day Rule

The CMS has stated that a locum tenens physician can provide services to Medicare patients for a continuous period of no longer than 60 days, with an exception made for temporary physicians filling in for a physician called to active duty in the Armed Forces. This 60-day count starts on the first day the locum tenens physician sees a patient, not when the regular physician takes their absence. If the locum tenens arrangement extends beyond 60 days, organizations can choose to enroll the locum tenens physician in the organization's contracted payer mix (including Medicaid) or have the absent physician return briefly to reset the 60-day window.

Frequently asked questions