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September 20, 2019
June 27, 2022

Quality patient care requires medical professionals around-the-clock staffing. Vacancies are a reality for any business; many healthcare facilities turn to locum tenens staffing to ensure consistent care.

As the popularity and need for locum tenens grows, there may still be confusion on how to bill for services.

Modifier Q6 and Billing for Locum Tenens

Billing typically falls under a Modified Q6 for Medicare claims processing. Most other commercial health insurance payers follow the Medicare rules and guidelines. If the payer hasn't adopted the guidelines, ask them how the billing should be handled, as they may have a process in place. Please note, most private and commercial payers require a credentialed physician that's enrolled soon after the staffing starts.

A regular physician can receive Part B payment for the services of a substitute physician (the locum tenens staffing) through Modifier Q6 if:

  • The regular (staff) physician is unavailable and can't provide the service, and the patient sought the service of the staff physician.
  • The locum tenens staff is paid for the service on a per diem, or fee-for-time, basis.
  • The service is provided in a medically underserved or rural area, or in a health professional shortage area. In this case, the Modifier Q6 would be attached after the CPT code.
  • The locum tenens physician has not provided services over a continuous period of more than 60 days. This service count starts at the time the substitute physician sees the first patient.

If the regular physician is called for duty in the Armed forces, there is no maximum limit on the substitute services provided by the locum tenens physician. There are a few simple guidelines you should follow when billing:

  • All claims should use the NPI of the regular physician.
  • The CPY/HCPCS codes will use the modifier Q6 appended.
  • A record of the service provided by the locum tenens physician should be filed with the substitute physician's NPI. When requested, this record should be available to the A/B MACs Part B.

The Latest Guidance from the Centers for Medicare and Medicaid Services (CMS)

In the past, the CMS allowed billing for locum tenens services beyond the 60-day limit if another locum tenens physician was used, resetting the 60-day limit. Recent rulings have made it clear that 60-days is the maximum limit for temporary staffing.

When locum tenens staffing is necessary beyond 60 days, you should quickly (if possible, before the service starts) enroll them in the contracted payer mix by applying for PAR (participation) status with the payers.

Keep in mind, enrollment takes time and the rules for back billing during enrollment may be different for each payer. After the 60-day substitute service window, you would bill like permanent staff using the locum tenens physician NPI number.

Getting Ahead with Locum Tenens Resources

Continue to deliver outstanding care to the community without sacrificing revenue or staffing time off with locum tenens staffing. Take the time to understand staffing needs before implementing a solution.

Contact Health Carousel Locum Tenens to learn more.