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Know Your Billing Rules for Locum Tenens

Thinking of taking some time off? A substitute physician, known as a ‘locum tenens’, can be hired to take over his/her practice when they are absent for reasons such as illness, pregnancy, vacation or continuing medical education.  There are a few rules of which to be aware. 

Physicians billing under locum tenens must make sure there is a definite break in coverage after 60 days of continuous coverage. For example, if a physician needs to be absent from his/her medical practice for 120 days, the absent physician may need to hire one locum tenens physician to work the first 60-day period and a different locum tenens physician to work the second 60-day period.

An exception to the 60-day limit is for physicians being called to active duty in the armed forces; there is no limit in such cases.  Another option in this case, and our Provider Enrollment advisor can further expand on, is to enroll the locum tenens physician with required payers such as Medicare and Medicaid.

Physicians cannot be practicing somewhere else while having a locum covering for him/her at their primary location.  Likewise, a locum tenens cannot be billed under a physician who is working the same day within the same location.  Such situations can prompt an audit, even if they can guarantee that there will be no concurrency issues.       

That is how auditors encounter incorrect locum tenens billing; a computer query can find a provider billed with and without the Q6 (locum) modifier on the same date of service, and if the result reflects he/she billed with and without the Q6 on the same date of service, it is considered a false claim.

Additionally, if a physician is out for 5 days but comes to work at noon on the fifth day, it is still a problem for a locum tenens to bill Q6 under his/her name for cases that morning, and bill under the physician name without Q6 that afternoon when he returns to work.  Legally, this can be billed.  Practically, from an audit risk standpoint, if the contractor runs a query, the physician will still show up as Q6 and non-Q6 on the same date of service, and that could prompt an audit.  If they audit, they will see that none of the actual case times overlap, but it is advised to avoid such situations completely.


By: Carolyn Wilson

Patient Registration Manager

On Tuesday, July 17, 2018

Categories: Compliance & Coding News

The information presented herein reflects general information that is current as of the date it was first published. Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

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