Physicians who use substitute billing arrangements can bill Medicare using the same substitute for more days than usual under flexibilities allowed during the COVID-19 public health emergency (PHE).
According to CMS, a physician (and physical therapists in some situations) can use the same substitute for the entire time he or she is unavailable to provide services during the COVID-19 emergency plus an additional period of no more than 60 continuous days after the public health emergency expires.
On the 61st day after the public health emergency ends (or earlier if desired), the regular physician or physical therapist must use a different substitute or return to work in his or her practice for at least one day in order to reset the 60-day clock. Typically, a physician can use one substitute for a total of only 60 continuous days before having to return to work or hiring a second substitute physician.
As usual, claims billed under substitute billing arrangements should include modifiers G5 for informal and reciprocal arrangements, or G6 for arrangements that involve per diem or other fee-for-time compensation (commonly known as locum tenens). As well, on the 61st and subsequent days that the same substitute physician is being utilized during or immediately after the public health emergency, modifier CR also should be used. The CR modifier is used for Part B billing to indicate a catastrophe/disaster-related circumstance.
To learn more generally about Medicare’s substitute billing arrangements, check out the following:
- CIPROMS blog post Locum Tenens Gets New Name and Expanded Guidelines.
- Changes to the Payment Policies for Reciprocal Billing Arrangements and Fee-For-Time Compensation Arrangements (formerly referred to as Locum Tenens Arrangements) MLN Matters Number: MM10090
For more information specifically related to COVID-19 PHE flexibilities, review the following documents:
- COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers (page 31)
- Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19) MLN Matters Number: SE20011
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