Temporary or quick start clinical staff
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1 Recorded May 14, 2014 Temporary or quick start clinical staff Jennifer Searfoss, J.D., C.M.P.E o e jen@scghealth.com
2 Objectives Explain locum tenens Provide several examples Clarify how that works with private insurance Identify resources
3 Medicare s locum tenens rule
4 What is locum tenens Since 1995, Medicare permits locum tenens billing for: Physician services Performed under Medicare Part B When a regular physician is absent and Replacement physician is paid on a per diem or other fee-for-time basis Replacement physician is duly licensed in the state
5 What is a physician Doctors of Medicine or Osteopathy Doctors of Dental Medicine Doctors of Dental Surgery Doctors of Podiatric Medicine Doctors of Optometry Chiropractor
6 Time period Continuous period of no longer than 60 days. The regular physician must return to work for the period to be reset. Most hospitals only grant temporary privileges for 60 days. If reset, this new period may not be covered by the temporary privileges granted by the hospital. Remember that temporary privileges take time for processing before granted. So temporary privileges may not begin at the start of the locum s work.
7 Clarifications Locum tenens arrangements are not available for services paid under Part A. Instead, Medicare enrollment isn t an issue and only requires the employment relationship. Locum tenens arrangements are not available for non-physicians. Instead, bill incident-to services while enrollment is pending Payment by a group practice is sufficient for reimbursement by the regular physician.
8 Billing - CMS1500 or UB04 Referral for image at time of service is regular physician Q6 modifier identifies the service of a locum NPI of the regular physician in all rendering spots
9 Documentation Charts do not need to be counter signed by a supervising physician or the absent physician Practice must document which services provided by locum tenens A log works great for easy retrieval if requested by CMS contractor Keep a copy of the agreement with the locums with the log
10 Scenarios and rule wrinkles
11 Scenario One Specialist is taking a leave of absence for maternity. Leave to be 3 months. Physician returning on day 59 for one day of service. Group contracts with a locum tenens physician licensed in state. Contract pays per diem for services with no rounding or on-call coverage. Locums to see only Medicare patients billing under specialists NPI. Meets Medicare requirements No privileging issues No private insurance issues
12 Private insurance Locum tenens is a Medicare only concept. Policies against it are not clear. Private insurance companies say that they only pay for services of duly credentialed, innetwork physicians and that claims must identify services performed by the specific individual physician. Aetna CIGNA Most Blues UnitedHealthcare
13 Scenario Two Three doctor practice with unexpected death of fourth owner. Hire in a new physician 45 days after death. Bill for services under senior physicians number. Does not meet the locums requirements Enrollment and credentialing required for all plans ( days)
14 Scenario Three Small group physician schedules retirement. While group hires a new physician, retiring physician contracts with a licensed locum tenens. Contract for 60 continuous days only paid by retiring physician on an hourly basis. Meets the locum tenens requirements Possible problem with private insurers. Call insurance companies. Possible problem with hospital. Call!
15 Scenario Four Solo physician brings in a new physician. While licensure, enrollment and credentialing applications are pending, physician bills under solo s number. Fraudulent billing DOES NOT MEET the locum tenens requirements Unlicensed professional practicing and opens to scrutiny by state board
16 Scenario Five Solo physician brings in a new physician assistant. While enrollment and credentialing applications are pending, licensed physician assistant bills under solo s number. Incident-to billing! No problem for Medicare. Does not meet locum tenens because this is for a non-physician practitioner.
17 Resources Incident-to billing: Gimme 15 Minutes webinar Medicare Internet Only Manual Medicare Claims Processing Manual, Chapter 1 Section H Section CMS.gov > Regulations and Guidance > Manuals > Internet-Only Manuals (IOMs) > > Chapter 1 General Billing Requirements
18 Questions Jennifer Searfoss, J.D., C.M.P.E o e jen@scghealth.com
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