CMS Locum Tenens Guidelines: Billing and Key Considerations
Today, we will discuss a topic that may cause some confusion for healthcare providers – locum tenens billing. While this may not be a lengthy post, it’s crucial to understand the guidelines CMS (Centers for Medicare and Medicaid Services) set forth when utilizing locum tenens. Although commercial payers often follow CMS guidelines, reviewing your specific payer contracts is essential to ensure compliance. Let’s dive into the basics of locum tenens and the key requirements to avoid any billing troubles in the future.
What is Locum Tenens?
Locum tenens refers to a substitute physician or practitioner who fills in for a regular provider during their absence, ensuring continuous patient care. The regular provider must be unavailable for reasons like pregnancy, vacation, illness, military deployment, or continuing education. Locum tenens allows patients to receive care as they would from their regular provider, even in their absence.
CMS Guidelines for Locum Tenens Billing:
Availability: The regular provider must be completely unavailable during the locum tenens coverage period.
Continuity of Care: The substitute practitioner must see patients who typically seek services from the regular provider.
Compensation: The locum tenens provider must be compensated per diem or for the service time they cover for the regular provider.
Time Limit: CMS allows a maximum of 60 days per calendar year for locum tenens coverage. This period can be consecutive or broken up into shorter periods.
Modifier Q6: When billing for services provided by the locum tenens practitioner, use modifier Q6 to indicate that a substitute physician performed the services.
Non-Affiliation: The locum tenens practitioner should not be an employee or directly affiliated with the practice or group; they must come from outside the organization.
Important Considerations:
Continuous Days: The 60-day time limit includes weekends and counts consecutively from the first day of patient care by the locum tenens provider.
Billing after 60 Days: Once the 60-day limit is reached, the regular provider cannot continue billing under their tax ID and MPI (Medicare Provider Identifier). All subsequent services must be billed using the locum tenens provider’s information.
Modifiers: Ensure you correctly apply modifier Q6 to the billed services using locum tenens coverage.
Non-CMS Payers: For non-Medicare payers, review your contracts and contact provider relations to determine their guidelines for locum tenens billing.
Locum tenens coverage is vital in maintaining continuous patient care when a regular provider is unavailable. Understanding CMS guidelines for locum tenens billing is essential to ensure compliance and avoid billing issues. Remember to use modifier Q6 to indicate the substitute physician’s services and closely follow the 60-day time limit. For non-CMS payers, consult your contracts and provider relations to determine their locum tenens billing requirements. You can confidently use locum tenens while providing uninterrupted patient care by doing your due diligence.
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