3-13-18 NAMAS Webinar Q&A Locum Tenens Reciprocal Billing

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

Moderators: Shannon DeConda, NAMAS Moderator

Post Reply
User avatar
Site Admin
Posts: 443
Joined: Mon Apr 09, 2012 1:54 pm

Tue Mar 13, 2018 3:04 pm

These questions have been answered by Paul Spencer, CPC, COC, and Jesse Overbay, JD.

1) We are a group of 4 Urologists. If one goes on vacation can we use a Locum Tenens physician for his patients and bill Medicare as such?

Yes. As long as the vacation does not extend beyond a period of 60 days, this is an acceptable use of a locum tenens physician.

2) for Reciprocal Billing? Does the patient go to the regular doctor's office or the substitute doctor's office? Or does it matter?

Typically, a reciprocal billing agreement is between physicians to cover each other’s practice when one or the other is absent. Place of service isn’t called out in the regulations, but if the service is being billed under a replaced physician with the Q5 modifier, the place of service that is attached to the replaced physician’s NPI should be used.

3) I have had a question asked of me regarding Locums being a preceptor for residents. If billing is under the provider that the Locums is filling in for (with the Q6 modifier), can the Locums doctor be a preceptor in the residency program?

The closest statement that we can find in the Medicare Claims Processing Manual is the following statement: “With respect to physicians, the term “covered visit service” includes not only those services ordinarily characterized as a covered physician service, but also any other covered items and services furnished by the substitute physician or by others as ‘incident to’ the physician’s services”. It is recommended that any teaching hospital considering the temporary replacement of a preceptor consult with legal counsel to consider the ramifications of a locum tenens in a preceptor role.

4) I am submitting a question regarding the length of time surrounding the absent physician departure and the start of a LT provider. If a physician leaves the practice and a LT provider is engaged, what is an acceptable length of time that can pass from the absent physician departure date until the start of a LT physician? Is there a time limit when a LT provider for the absent physician is no longer an option? Generally speaking, LT provides for an absent physician who will be returning following vacation, illness, leave and similar circumstances. In the case of a departing physician, there will be no ‘return to work’ date.

The only time span spelled out in the regulations is 60 days of replacement time by a locum tenens physician. The clock therefore starts on Day 1 of the locum tenens physician providing services in place of the retired physician.
Post Reply