There are two ways to bill Medicare when using a locum tenens provider, depending on the situation.
One is to set up the locum tenens physician with their own NPI and the other is to use the NPI of the physician they are replacing, plus the Q6 modifier code.
This Q6 code is only allowed to be used for a 60-day period, at which time either the replaced physician or another locum tenens physician needs to come into work for at least a day before the original locum tenens physician can come back and again be billed under Q6 – this resets the 60-day limit. What do you do if a reset isn’t possible, and you want to keep using the same locum tenens provider as a replacement beyond 60 days?
Unless the physician being replaced is on active military duty (which waives the 60-day limit), you will need to bill Medicare using the locum tenens physician’s NPI.
In addition, any time a locum tenens provider is working in the place of another physician for longer than 60 days, you need to have a contract that includes joint and several liabilities and ensures access to claims submitted by the entity for the services provided by the locum tenens physician.
Here is a sample of the clause needed:
Physician and Client will have joint and several liabilities for any Medicare overpayment relating to claims made for Physician’s services, but Client will hold Physician harmless for any such liability.
A physician shall have unrestricted access to claims submitted by the client for services provided by the Physician.
Knowing which billing method to use when can be tricky, so we’ve mapped it out for you below.