When your doctors decide to take a vacation, Medicare allows you to bring in a temporary replacement, if necessary, to keep the practice running. You can bill the services of the replacement, known as a locum tenens physician, using the physician identification number of the doctor who is away.

Locum tenens is a Latin phrase that translates as “in the place of.” Stay on top of key Medicare rules for the use of locum tenens physicians:

Locum stay is limited to 60 consecutive days. Medicare rules state the locum tenens physician may work in your practice as a locum for only 60 consecutive days. If the locum is subbing for a doctor who will return to the practice, you can use the same locum tenens physician if your doctor returns, then leaves again.

Use the –Q6 modifier and keep records of the locum’s work: Bill for services furnished by the locum tenens physician with the –Q6 modifier in Box 24d of the CMS-1500 form, CMS says in Chapter 4, Section 30.2.11 of the Internet Only Manual (IOM). Enter the PIN of the physician being replaced in Box 24k. You must keep track internally of the unique provider identification number (UPIN) of the locum tenens physician and have that information available on request.

Locum tenens is for doctors only: You cannot employ a locum tenens to replace a non-physician practitioner. Medicare allows locum tenens only for physicians. Make sure the locum doctor documents his own services – you could be in for real trouble if an auditor spots the handwriting of one of your NPPs in the locum’s notes.

Locum tenens can be used temporarily for a physician who is not coming back: Medicare’s revised IOM (Chapter 4, Section 30.2.11) makes it clear that you can use a locum tenens doctor as a temporary replacement for a physician that has left the group, but the locum still cannot stay longer than 60 days before being replaced by another locum tenens doctor. Be wary of cycling out temporary physicians without filling a vacancy. It may be legal, but could draw scrutiny from your carrier. If you find you need another permanent physician, hire one.

Don’t use another permanent employee as a locum tenens: Medicare rules are clear that the locum tenens physician should be paid by “per-diem or fee-for-time compensation.” Don’t assign a permanent employee physician awaiting credentials to act as the locum tenens for another physician.

These rules apply to Medicare only: Don’t assume that your other payers follow Medicare’s lead when it comes to locum tenens policy or you may be in for a surprise. Locum tenens is a Medicare policy, and your private payers may have different guidelines – check with them before submitting locum claims.

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