Q&A: How to bill for a locum tenens during a transition period

Key Points

Q: We have a physician leaving our practice and a new physician who is joining, and we are confused regarding how we should bill for services during this transition? I read that we can bill the new doctor as a locum tenens for the departing doctor until the new doctor has his provider number. I also understand that if we are credentialing a new doctor to Medicare and Medicaid, we can use modifiers to bill for those services during the credentialing process. Can you help?

A: There are actually several questions within your question, so I will try to differentiate and clarify each one. My response is based on Medicare's rules regarding locum tenens and credentialing. Private insurers may have their own rules about covering physicians and payment to physicians who are not yet credentialed with the insurer, and you need to verify those rules with the insurer.

• A practice may bill for a locum tenens physician using the provider number of the absent physician (vacation, medical leave, etc.) for up to 60 continuous days. The presumption is that the absent physician will return. A locum tenens physician must be a credentialed Medicare provider (other than for your practice), and a record of that physician's National Provider Identifier should be on file with the carrier. Locum physicians should not have a practice of their own. The services must be billed using the modifier –Q6 to show that it is a locum tenens physician, and a record of the services provided to your patients by the locum tenens physician must be kept. The locum tenens physician is considered an independent contractor, and compensation must be based on a fixed amount (such as a per diem). After 60 continuous days, locum tenens physicians may no longer see patients or bill for services with anything other than their own NPI specifically attached to your practice and Tax ID number.

• There are no modifiers that can be used to bill the services of an uncredentialed provider, whether new to your practice or new to Medicare and Medicaid. In the past, the process to bill those services has been to retroactively bill for the services once the provider obtained an NPI and the credentialing process was completed. This was because the filing limit was one year for Medicare services. Effective January 1, 2009, that filing limit was reduced to 30 days. If a credentialed provider has joined your practice from another practice, you can use that physician in a locum tenens capacity for a continuous period of 60 days (including days when no patients are treated or seen) using modifier –Q6 during the credentialing process, provided the departing physician has not deactivated his affiliation with you. At the end of the 60-day period, the new provider must have his own NPI to continue to bill for services rendered.

The author, vice president of operations for Reed Medical Systems in Monroe, Michigan, has more than 30 years of experience as a practice management consultant, and is also a certified coding specialist, certified compliance officer, and a certified medical assistant.