The verifications department at a locum tenens firm
A locum tenens firm’s verification department is integral in verifying the quality of candidates being submitted to health care organizations (aka the clients of the locum tenens organization) for their coverage needs. Practitioner candidates working through a locum tenens firm will be endorsed on the firm’s professional liability insurance policy.
To determine if a potential candidate can be approved to practice under the firm’s policy, they are required to complete a verification packet. This packet includes items such as a Release of Authorization form, used when verifying a candidate’s credentials and a malpractice application. This form asks the candidate to give details of their education/training, work history/affiliations, malpractice history and asks the candidate disclosure questions relating to their current and past medical practice history.
Moving from the big picture to the smaller picture, let’s take a look at how this process works at one organization: Delta Locum Tenens. Unlike most Locum firms, prior to submitting a candidate for approval, Delta Locum Tenens will retype the curriculum vitae to include all months/years of education, medical work history and explanation for any gaps over 30 days. Delta Locum Tenens also creates a provider summary. The Provider Summary is a document that consists of the results that were found in the initial screening of the candidate. Board certification, status of all active and inactive state medical licensure and controlled substance registrations, and details of any past malpractice claims and background/licensure issues are fully documented. In addition, candidates are run through the Excluded Parties List System (EPLS) and Office of Inspector General (OIG) to check for any sanctions regarding Medicare/Medicaid or any other federally funded program. Peer references are also obtained on the candidate. After the curriculum vitae, provider summary, and background info are obtained, the provider is eligible to begin the assignment.
About the Author: Tiffany Chimal is a Senior Privileging Coordinator with Dallas, Texas-based Delta Locum Tenens. For more information on Delta Locum Tenens, visit www.deltalocums.com or http://blog.deltalocums.com.
Casey Roark | Mar 6, 2009 | Reply
How do bill for locums used as hospitalist who work for more than 2 months? Medicare states you can only bill for a patient care need after another provider resigns or to cover an illness (i.e. leave of absence, etc.)
Katie Abby | Mar 9, 2009 | Reply
Casey, there are two ways a healthcare organization can receive reimbursement for the services of a locum tenens physician (reassignment). The first is called the Locum Tenens Exception. The second, Payment for Services Provided under a Contractual Agreement.
The Locum Tenens Exception provides that Medicare may pay a patient’s “regular” physician for the services of a locum tenens physician during the absence of the regular physician when the regular physician is paying the locum tenens on a per diem or similar fee-for-time basis. The regular physician bills for the locum tenens’ services by entering by entering HCPCS code modifier Q6 (service furnished by a locum tenens physician) after the procedure code. The substitute physician’s NPI is also required.
The drawback to the Locum Tenens Exception is a 60-day limit you mentioned on services provided in the regular physician’s place. (Note: A six-month extension has been added to this limit for physicians on active military duty.)
Many if not most of the vacancies you are filling these days are expansion or vacant positions. There may not be a “regular” physician to bill under. And, filling these openings in 60 days is near impossible—ok, completely impossible—in most cases.
The Contractual Agreement provision states that Medicare may make a payment to an entity ( i.e., a person, group, or facility) enrolled in the Medicare program that submits a claim for services provided by a physician under a contractual arrangement with that entity, regardless of where the service is furnished. The service may be furnished on or off the premises of the entity submitting the bill. This eliminates the 60-day limit, and allows healthcare organizations to bill for the services of locum tenens in clinics, outpatient facilities, and their other physical locations.
Medicare includes two “integrity safeguards” in this provision, one that links the physician and the organization in responsibility for the accuracy of claims submitted and one that ensures physicians access to claims submitted on their behalf. Here is the specific language about what should be included in the contract:
1. Joint and several liability is shared between the entity submitting the claim and the person actually furnishing the service, for any Medicare overpayment relating to such claim.
2. The person furnishing the service has unrestricted access to claims submitted by the entity for the services provided by that person.
It is understandable that physicians may balk at the idea of holding joint responsibility of claims they do not actually submit. It’s natural to resist being responsible for something over which you have no control.
Our solution is to include the required language in physicians/healthcare organization contracts, and then to add language that eases these concerns. We use the following language in our Placement Letters, and encourage you to add similar language to any contracts you hold with interim physicians:
“Physician and Client will have joint and several liability for any Medicare overpayment relating to claims made for Physician’s services, but Client will hold Physician harmless for any such liability. Physician shall have unrestricted access to claims submitted by Client for services provided by Physician.”
We think this language satisfies Medicare’s requirements and makes locum tenens coverage feasible and affordable for your organization. Casey, don’t hesitate to give us a call if we can offer further clarification or assistance.
Katie Abby
Executive Vice President
VISTA Staffing Solutions
800-366-1884
Tiffany Chimal | Mar 9, 2009 | Reply
Hi Casey,
Thank you for posting. According to the CMS, the information below pertains to your question:
A. Background
It is a longstanding and widespread practice for physicians to retain substitute physicians to take over their professional practices when the regular physicians are absent for reasons such as illness, pregnancy, vacation, or continuing medical education, and for the regular physician to bill and receive payment for the substitute physician’s services as though he/she performed them. The substitute physician generally has no practice of his/her own and moves from area to area as needed. The regular physician generally pays the substitute physician a fixed amount per diem, with the substitute physician having the status of an independent contractor rather than of an employee. These substitute physicians are generally called “locum tenens” physicians.
Section 125(b) of the Social Security Act Amendments of 1994 makes this procedure available on a permanent basis. Thus, beginning January 1, 1995, a regular physician may bill for the services of a locum tenens physicians. A regular physician is the physician that is normally scheduled to see a patient. Thus, a regular physician may include physician specialists (such as a cardiologist, oncologist, urologist, etc.).
B. Payment Procedure
A patient’s regular physician may submit the claim, and (if assignment is accepted) receive the Part B payment, for covered visit services (including emergency visits and related services) of a locum tenens physician who is not an employee of the regular physician and whose services for patients of the regular physician are not restricted to the regular physician’s offices, if:
• The regular physician is unavailable to provide the visit services;
• The Medicare beneficiary has arranged or seeks to receive the visit services from the regular physician;
• The regular physician pays the locum tenens for his/her services on a per diem or similar fee-for-time basis;
• The substitute physician does not provide the visit services to Medicare patients over a continuous period of longer than 60 days subject to the exception noted below; and
• The regular physician identifies the services as substitute physician services meeting the requirements of this section by entering HCPCS code modifier Q6 (service furnished by a locum tenens physician) after the procedure code. When Form CMS-1500 is next revised, provision will be made to identify the substitute physician by entering his/her unique physician identification number (UPIN) or NPI when required to the carrier upon request.
EXCEPTION: In accordance with section 116 of the “Medicare, Medicaid, and SCHIP Extension Act of 2007” (MMSE), enacted on December 29, 2007, the exception to the 60-day limit on substitute physician billing for physicians called to active duty in the Armed Forces has been extended for services furnished from January 1, 2008 through June 30, 2008. Thus, under this law, a physician called to active duty may bill for substitute physician services from January 1, 2008 through June 30, 2008 for longer than the 60-day limit.
If the only substitution services a physician performs in connection with an operation are post-operative services furnished during the period covered by the global fee, these services need not be identified on the claim as substitution services.
The requirements for the submission of claims under reciprocal billing arrangements are the same for assigned and unassigned claims.
C. Medical Group Claims Under Locum Tenens Arrangements
For a medical group to submit assigned and unassigned claims for the services a locum tenens physician provides for patients of the regular physician who is a member of the group, the requirements of subsection B must be met. For purposes of these requirements, per diem or similar fee-for-time compensation which the group pays the locum tenens physician is considered paid by the regular physician. Also, a physician who has left the group and for whom the group has engaged a locum tenens physician as a temporary replacement may bill for the temporary physician for up to 60 days. The group must enter in item 24d of Form CMS-1500 the HCPCS modifier Q6 after the procedure code. Until further notice, the group must keep on file a record of each service provided by the substitute physician, associated with the substitute physician’s UPIN or NPI when required, and make this record available to the carrier upon request. In addition, the medical group physician for whom the substitution services are furnished must be identified by his/her provider identification number (PIN) or NPI when required on block 24J of the appropriate line item.
Physicians who are members of a group but who bill in their own names are generally treated as independent physicians for purposes of applying the requirements of subsection A for payment for locum tenens physician services. Compensation paid by the group to
the locum tenens physician is considered paid by the regular physician for purposes of those requirements. The term “regular physician” includes a physician who has left the group and for whom the group has hired the locum tenens physician as a replacement.
Please don’t hesitate to contact me if you have any additional quetsions.
Tiffany Chimal
Umendra Singh | Mar 21, 2009 | Reply
A promise of compensation for specific potential future losses in exchange for a periodic payment.Guarding against property loss or damage making payments in the form of premiums to an insurance company, which pays an agreed-upon sum to the insured in the event of loss.
Renee Mickens | Apr 1, 2009 | Reply
Are there any rules relating to not being able to bill Medicare Part B claims to for an Active Military Physician?
Jeff | Apr 3, 2009 | Reply
When using a locums physician…is the locums physician required to be enrolled with Medicare and have a Medicare number before he can provide locums services? (One would assume the physician he is standing in for has a Medicare number.)
Justina Dombrowski | May 15, 2009 | Reply
Katie,
This is great information. We terminated a physician from our group in January and hired a locums from Vista. We thought we could bill Medicare under the previous physician for 60 days. We are now learning that the previous physician disenrolled from Medicare upon her termination, thus causing our claims to be denied. We are still without a permanant physician and not being paid by Medicare. Are you saying that we can still be paid? Is this a different method of billing, or do we need to do some type of special enrollment?
Thank You!
Justina Dombrowski
Clinic Manager, California Medical Group
Dana Harden | Jun 8, 2009 | Reply
Is there a privileging time limit for a locums who is filling a vacant position? Does the temporary privileges time limit of 120 days apply to locums?
Dr.Montes | Jun 25, 2009 | Reply
Is the locum tenens physician required to be enrolled in Medicare. I am retired and have lapsed my enrollment but have opportunity as locum tenens.
Tiffany Chimal | Aug 3, 2009 | Reply
Hi Dana,
The time limit for a locums physician varies according to your facility’s bylaws. From my experience, temporary privileges for a locum are anywhere from 30 – 120 days. Check with your facility’s administrator to determine what your Board has set forth as the time frame for when the privileges are effective and when they expire. It seems to me as if these privileges are granted for a specific period in sync with when the credentialing, medical executive, and Board of Trustees committees can meet and formally grant the physician privileges after reviewing his/her file.
Tiffany Chimal | Aug 3, 2009 | Reply
Hi Dr. Montes,
No, typically a locum tenens physician is not required to be enrolled in Medicare initially. If you are required to be enrolled, the facility where you are being credentialed at will enroll you in Medicare once you initiate the credentialing process with them. They will then follow up with you as needed if they need additional documents reviewed and signed by you and to give you your Medicare number(s).
mary floyd | Oct 26, 2009 | Reply
we are having a dilemma in our urology office. We own a oncology center with another practice, and our oncologist is leaving 12/22/09. we are looking for a locum tenens to fill for 60 days. Do we bill Medicare under the oncologist that left the practice or under our referring urology physician?
ca confused | Oct 30, 2009 | Reply
If the provider is joining a practice who is not contracted with any insurance on their own or credential w/ mcare. is it legal to bill under another md in the practice. similar to a pa supervised by a md.
thanks