Misinformation continues to surround use of the Q6 modifier or the billing for services provided by a locum tenens physician. This can result in mistakes that prove costly or even detrimental to practices, as they may result in audits or further disciplinary action.
The Q6 modifier is intended to be a tool that practices can use when a physician is away for an extended period of time, therefore requiring temporary coverage by a locum tenens. It covers Part B fees or medical claims related to the professional service provided, which are billed using the existing physician’s NPI number and the Q6 modifier.
To prevent abuse, there are stringent rules in place surrounding the conditions for using this modifier. When it is used, the surrounding circumstances must be well-documented. Carefully review the details associated with when and how to use the Q6 modifier to ensure that you remain compliant.
A locum tenens physician may be called in when the primary physician is unable to provide regular services to their patients. The circumstances that may prompt such leave are broad, and may include: illness, pregnancy, vacation, CME participation, bereavement, and so forth.
However, there are other conditions that must be in place for use of the Q6 modifier.
The Q6 modifier allows for a maximum billing of sixty (60) continuous days. The only exception to this is when the regular physician is on active military duty, in which case the restriction is waived and the Q6 modifier can be used for a longer period of time. After sixty billed days, the Q6 modifier can no longer be used to pay for locum tenens services for that physician's absence. Additionally, you can’t use another physician to extend coverage at the end of 60 days, and the existing physician cannot have been gone for more than ninety (90) days.
The locum tenens physician must be paid per day, although this may be done directly or through an agency. They cannot be self-employed or working for another practice, and they must be a physician — not a nurse practitioner, physician assistant, or any other occupation.
What happens if you need to extend coverage past 60 days or the primary physician chooses not to return? For example, a permanent physician may be using FMLA leave and taking 90 days off from work or may decide to take another job while on leave. In either case, the temporary physician is no longer considered a true locum tenens after 60 days, and services can’t be billed under the Q6 modifier. Instead, the temporary physician must be enrolled with payers and services should be billed under their own individual NPI number. The physician is now considered an interim provider, as he or she is now filing a vacancy rather than providing replacement coverage.
It’s best to begin the payer enrollment process during the initial 60 days. This helps you avoid any gaps in coverage, as well as any compliance issues for using the primary physician’s NPI number past the allowed time.
There are two critical steps associated with using the Q6 modifier, in order to properly note that another physician is filling in for the regular physician:
Always check with the insurance carrier, as they may have their own guidelines in addition to the ones listed here. This is true for Medicaid and Medicare as well as privately contracted plans.
Best practice is to create a protocol for your staff to use the Q6 modifier and also retain the necessary documentation in case of an audit. It's best to not leave any room for misunderstanding of these instructions.
It is essential to follow the rules associated with the Q6 modifier, respecting both the terms for its use while also ensuring that the appropriate documentation measures are taken. Lack of compliance can result in errors that might put your practice in jeopardy of an audit or take-back.
The guidelines and instructions provided here are intended to help get you on track to using the Q6 modifier while remaining compliant. For detailed information on submitting claims for locum tenens physicians, check out the Centers for Medicare & Medicaid Services (CMS) Manual System.