Are you affiliated with one of the growing numbers of medical practices or healthcare facilities that require the services
of a locum tenens physician? More and more practitioners are accepting locum tenens assignments and providing coverage for
doctors during vacations, continuing medical education seminars, and leaves of absence for illness or pregnancy. However,
when it comes time to invoice Medicare for these services, many billing administrators fail to receive reimbursement.
In the following discussion, an industry billing expert shares her insights on how to properly process Medicare claims for
services rendered by locum tenens practitioners. Hopefully, these suggestions will help members of your organization to avoid
some of the more common filing pitfalls.
A PRIMER ON PROCESSING
The enactment of Section 125(b) of the Social Security Act Amendments of 1994 has enabled physician practices and healthcare facilities to bill Medicare for the services of locum tenens physicians. According
to the Centers for Medicare and Medicaid Services (CMS), a locum tenens or substitute physician is a practitioner who is paid
a fixed amount per diem by the core physician, practice, or contract facility, and holds the status of an independent contractor.
With 24 years of processing experience, Barbara Puleo, coordinator of credentialing and contracting for Evolutions—a medical
billing firm in St. Louis, Missouri—explains, "Medicare claims for reimbursement of locum tenens services are submitted under
the core physician's name and a detailed record should be kept of each charge. For audit purposes, the account should include
the covering physician's full name, uniform professional identification number (UPIN), social security number, date of birth,
and state medical license number."
FROM THE LOCUM TENENS PERSPECTIVE
Philip Bakody, MD, a locum tenens radiologist currently working with JCNationwide, based in Atlanta, Georgia, notes that the
facility or practice contracting his services generally handles the Medicare claims. "From my experience, the hospital or
clinic typically bills Medicare for such services
as radiographic interpretation or an angiogram. As part of my locum tenens agreement, I usually assign payment over to the
contracted facility or practice. They, in turn, use my Medicare number to process claims and the payment is sent directly
to them."
SOLO AND GROUP PRACTICES
CMS requires that anyone filing claims for professional locum tenens services use the HCFA 1500 claim form. To receive payment,
it is essential that the processor enter a Q6 modifier—which indicates the filing is for locum tenens services—under item
24d after the procedure code (CPT). The core physician is identified by his or her provider identification number (PIN), which
is entered on block 24k of the HCFA form.
While Dr. Bakody has rarely had occasion to work over 2 weeks on any contract, there are other physicians who have accepted
longer assignments. If locum tenens coverage extends beyond 60 consecutive days, the core doctor filing Medicare claims is
not entitled to bill or receive direct payment for the extended time. In this case, the locum tenens doctor is considered
a core physician and must be enrolled in and bill Medicare under his or her own name. Of course, this situation only applies
when services continue without interruption; if a different locum tenens physician assumes coverage on behalf of the staff
doctor, a new 60-day period would ensue. Currently, there is no limit to the number of different locum tenens doctors who
can provide coverage to the regular physician.