If you’ve been using locum tenens arrangements to help your practice with temporary physician absences, you’ll want to take note of a name change by the Centers for Medicare and Medicaid Services (CMS).
According to a recent change request published by CMS, the term “Locum Tenens Arrangements” was used in the 21st Century Cures Act to describe both the per diem or fee-for-time compensation arrangements that were commonly referred to as “locum tenens” as well as other reciprocal billing arrangements. As such, CMS has discontinued the use of the term for just the one type of arrangement in order to avoid confusion. Beginning with June 13, 2017, services previously referred to as locum tenens are now simply called “fee-for-time compensation arrangements.”
Also included in the 21st Century Cures Act was an expansion of the guidelines for fee-for-time compensation and reciprocal billing arrangements. Now, outpatient physical therapy services furnished by physical therapists (PTs) in a Health Professional Shortage Area (HPSA), a Medically Underserved Area (MUA), or a rural area can be provided under these same alternate compensation arrangements lumped under “Locum Tenens Arrangements.”
As with physicians, fee-for-time compensation arrangements for PTs in a HPSA, MUA, or a rural area are limited to 60 days, unless the provider who is away has been called or ordered to active duty as a member of a reserve component of the Armed Forces. The same guidelines applies to reciprocal billing arrangements.
Also, the modifiers Q5 and Q6 should be used for all providers (both physicians and PTs) utilizing the reciprocal billing or fee-for-compensation arrangements, respectively. However, until the Q5 and Q6 modifier descriptors have been updated to include PTs, MACs will accept claims for qualified physical therapy services only if they are reported with a Q5 or Q6 modifier whose descriptor references only physicians.
While no other changes have been made to the fee-for-time compensation arrangements, we wanted to remind you of a few other guidelines, as highlighted in Medicare Administrative Contractor WPS-GHA’s Frequently Asked Questions webpage.
- Reciprocal and fee-for-time compensation arrangements are billed to Medicare under the credentials of a physician who is employed by a group or practice but is on an extended leave. The physician who is “filling in” is NOT employed by the group and usually is paid a per diem rate.
- As mentioned above, reciprocal and fee-for-time compensation arrangements are limited to 60 days. After one substitute physician has exhausted his 60-day limit, however, the practice may contract with another substitute for another 60 days.
- Physicians and PTs operating under reciprocal and fee-for-time compensation arrangements do not have to be enrolled in Medicare. However, they must have a National Provider Identifier (NPI) and an unrestricted license in the state in which they are practicing.
- Fee-for-time compensation arrangements do not apply to deceased providers. “When a physician becomes deceased, his/her billing number, NPI and enrollment are deactivated and cannot be used after the date the physician passes away, therefore, a fee-for-time arrangement would not be permitted for a deceased provider.”
- The group or practice for whom the provider is filling in must maintain a record of each service provided by the substitute physician, along with the substitute physician’s NPI number, which can be made available to Medicare upon request.
For more information about the change to the name or guidelines of locum tenens/fee-for-time compensation arrangements mandated by the 21st Century Cures Act, refer to the MLN Matters Article “Changes to the Payment Policies for Reciprocal Billing Arrangements and Fee-For-Time Compensation Arrangements (formerly referred to as Locum Tenens Arrangements)” or to the CMS Manual Change Request 10090, both from May 12, 2017.
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