If you’re not using modifier Q6 correctly, you could be leaving thousands of dollars or more on the table. This modifier (and its proper use) is crucial to getting deserved reimbursement for locum tenens services. Don’t let a physician’s illness or vacation devastate your practice’s bottom line!
“Locum tenens” is Latin for “one holding a place” and has long been the term that the Centers for Medicare & Medicaid Services (CMS) has used to refer to a physician who temporarily fills in for another, according to coding expert Jill Young in the ProfEdOnDemand training session, “Locum Tenens: How to Do Short-Term Help the Right Way.” Billing and accurately coding locum tenens services isn’t exactly easy – you need to follow CMS’ strict guidelines and understand how and when to append modifier Q6.
Make Sure Sub Physician Meets the Criteria
Utilizing a substitute (locum tenens) physician from time to time in a practice is rather common. Your practice may need a locum tenens physician due to the regular physician’s illness, pregnancy, vacation, or even continuing medical education, according to a summary by CGS Medicare. To obtain proper payment for a locum tenens physician’s services, you must follow strict coding and billing rules.
How it works: Typically, the regular physician would submit a claim under her own National Provider Identifier (NPI), using the proper procedure codes and the Healthcare Common Procedure Coding System (HCPCS) modifier Q6, CGS instructed. Then, the regular physician would receive the payment for the service and pay the locum tenens physician for her services on a per diem or similar fee-for-time basis.
The basics: Under CMS’ rules, the locum tenens physician should have no practice of her own and moves from area to area as needed, CGS stated. She should have an independent contractor status rather than that of an employee and would receive payment from the regular physician on a fixed amount per-diem. Also, a locum tenens physician provides services to Medicare patients over a continuous period of no longer than 60 days.
Study CMS’ Q6 Guidelines
Requirements: So when you have replacement of an existing physician, you must follow certain guidelines to use the Q6 modifier correctly, according to a recent tutorial by All Star Recruiting. To properly append the Q6 modifier, the following conditions must apply:
- The regular physician is unavailable to provide services to patients;
- You paid the locum tenens for her services on a per-diem or similar basis (can also be through an agency);
- The only exception of the 60-day rule for a substitute physician is in cases of a physician’s extended active military duty;
- The regular physician is gone for no longer than 90 days;
- You cannot use another physician to extend coverage at the end of 60 days;
- You cannot use the modifier if you didn’t initially have a regular physician (as in the case of an expansion);
- The locum tenens physician seeing patients is not in practice for herself or employed as part of another practice; and
- The modifier does not apply to Nurse Practitioner or Physician Assistant services.
Important: Keep in mind that the above rules apply to Medicare and Medicaid, and they may not apply to commercial payers, All Star Recruiting noted. You must check with each of your payers to determine how to code locum tenens services properly.
Why ‘Locum Tenens’ Term is Obsolete
Even though the term “locum tenens” is still commonly used in the healthcare industry, CMS has actually changed locum tenens to “fee-for-time compensation arrangements,” effective for services on or after June 13, 2017, noted a recent CIPROMS Medical Billing blog posting by Charity Singleton Craig.
The name change is supposed to better encompass both locum tenens arrangements and other reciprocal billing arrangements.
What’s more: CMS made a few other revisions to the locum tenens rules, including that the substitute physician must have an NPI and an unrestricted license in the state where she’s practicing, but doesn’t need to be enrolled in Medicare, Craig noted. Also, fee-for-time compensation arrangements don’t apply to deceased providers, and the group practice must keep a record of each service the substitute physician provides along with her NPI number.
Bottom line: To nab proper reimbursement for services that another physician provides while a regular physician is away, make sure you know how and when to use the Q6 modifier, how long you can bill for the locum tenens services, who qualifies as a locum tenens, and what documentation you need to keep, Young stresses. If you don’t get all these elements right, you’ll lose out on vital payments.