Temporary or quick start clinical staff
Jennifer Searfoss, J.D., C.M.P.E
o 888 886 8054 e [email protected]
Objectives
• Explain “locum tenens” • Provide several examples
• Clarify how that works with private insurance • Identify resources
What is “locum tenens”
• Since 1995, Medicare permits locum tenens billing for:
– Physician services
– Performed under Medicare Part B
– When a “regular physician” is absent and
– Replacement physician is paid on a per diem or other fee-for-time basis
What is a “physician”
• Doctors of Medicine or Osteopathy • Doctors of Dental Medicine
• Doctors of Dental Surgery
• Doctors of Podiatric Medicine • Doctors of Optometry
Time period
• “Continuous period of no longer than 60 days.”
– The “regular physician” must return to work for the period to be reset.
– Most hospitals only grant temporary privileges for 60 days.
• If “reset,” this new period may not be covered by the temporary privileges granted by the hospital.
• Remember that temporary privileges take time for
processing before granted. So temporary privileges may not begin at the start of the locum’s work.
Clarifications
• Locum tenens arrangements are not available for services paid under Part A.
– Instead, Medicare enrollment isn’t an issue and only requires the employment relationship.
• Locum tenens arrangements are not available for non-physicians.
– Instead, bill incident-to services while enrollment is pending
• Payment by a group practice is sufficient for reimbursement by the “regular physician.”
Billing - CMS1500 or UB04
NPI of the regular physician in all rendering spots Referral for image at time of
service is regular physician
Q6 modifier identifies the service of a locum
Documentation
• Charts do not need to be counter signed by a supervising physician or the absent physician
• Practice must document which services provided by locum tenens
– A log works great for easy retrieval if requested by CMS contractor
– Keep a copy of the agreement with the locums with the log
Scenario One
Specialist is taking a leave of absence for maternity. Leave to be 3 months. Physician returning on day 59 for one day of service.
Group contracts with a locum tenens physician licensed in state. Contract pays per diem for
services with no rounding or on-call coverage. Locums to see only Medicare patients billing under specialists NPI.
Meets Medicare requirements No privileging issues
Private insurance
• Locum tenens is a Medicare only concept.
– Policies against it are not clear.
• Private insurance companies say that they only pay for services of duly credentialed,
in-network physicians and that claims must
identify services performed by the specific individual physician.
Aetna Most Blues
Scenario Two
Three doctor practice with unexpected death of fourth owner. Hire in a new physician 45 days after death. Bill for services under senior
physicians number.
Does not meet the locums requirements Enrollment and credentialing required for all plans (45-120 days)
Scenario Three
Small group physician schedules retirement. While group hires a new physician, retiring
physician contracts with a licensed locum tenens. Contract for 60 continuous days only paid by
retiring physician on an hourly basis.
Meets the locum tenens requirements Possible problem with private insurers.
Call insurance companies.
Scenario Four
Solo physician brings in a new physician. While licensure, enrollment and credentialing
applications are pending, physician bills under solo’s number.
Fraudulent billing
DOES NOT MEET the locum tenens
requirements
Unlicensed professional practicing and
Scenario Five
Solo physician brings in a new physician
assistant. While enrollment and credentialing applications are pending, licensed physician assistant bills under solo’s number.
Incident-to billing! No problem for Medicare.
Does not meet locum tenens because this is for a non-physician practitioner.
Resources
• Incident-to billing: Gimme 15 Minutes webinar • Medicare Internet Only Manual 100-04
– Medicare Claims Processing Manual, Chapter 1
• Section 30.2.1.H • Section 30.2.11
CMS.gov > Regulations and Guidance >
Manuals > Internet-Only Manuals (IOMs) > 100-04 > Chapter 1 – General Billing
Questions
Jennifer Searfoss, J.D., C.M.P.E o 888-886-8054
