Abusing Locum Tenens Billing

Original story posted on: June 15, 2020

I was shocked, and very concerned when I recently looked at a physician department staffing sheet of a client. 

Three of 12 positions had “locum” entered into the space for physician names. Digging a little deeper, I found out that since they had not been able to fill these positions, they had covered the services using a physician staffing service that continued to bill under the name of a physician who had retired from the hospital. 

Locum tenens is Latin for “place holder.” In medicine, using the term was initiated to allow physicians to take time off for vacations and other personal reasons, without replacing the physician. Additionally, the idea was that while the physician being covered was away, he or she paid the “locum tenens” physician to take over their responsibilities. That is why physicians being covered by another physician under a locum tenens agreement continued billing under their billing number.

You might wonder why the hospital did not simply bill under the number for the physician from the temporary agency. In order to bill that way, they would have to have had them credentialed. The current backlog with their Medicaid managed care group was six months, in the state in which the hospital was located.

Section 30.2.11 of the Medicare manual covers billing for locum tenens services. It allows a practice to bill for temporary physician services during the absence of a regular physician who normally would have been scheduled to see a patient. For this type of reimbursement to take place, the regular physician arranges coverage for no longer than 60 continuous days, and then enters HCPCS code modifier Q6 after the procedure code during the billing process. 

Despite the tremendous need, using the locum tenens service eventually caught up with this hospital. The Medicaid managed care plan noticed that the hospital was billing under a physician number after the 60-day cutoff, and started denying claims. Even worse, the Medicaid managed care plans found out that the physician whose number they were billing under had retired. The physician’s license was still valid for a while more, but they were no longer practicing medicine.   

What should hospitals do about locum tenens billing? First, make sure your credentialing department keeps a list of all locum physicians. See if there is a plan in place to credential physicians who might exceed the 60-day limit. Make very sure that the locum modifier is being used for services provided by locums. Finally, make sure that locum tenens billing is addressed in your compliance plan.

Programming Note: Listen to Timothy Powell report the latest healthcare news on Talk Ten Tuesdays, 10-10:30 a.m. EST.

Timothy Powell, CPA

Timothy Powell is a nationally recognized expert on regulatory matters, including the False Claims Act, Zone Program Integrity Contractor (ZPIC) audits, and U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance. He is a member of both the RACmonitor and ICD10monitor editorial boards and a national correspondent for both Monitor Mondays and Talk Ten Tuesdays.

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