A locum tenens provider is someone who does not own their practice but serves as a travelling provider filling in for other providers who are unable to work due to a variety of reasons, including illness. Locum tenens is now referred to as Fee-For-Service Time Compensation physicians who serve as substitute. [1] These providers are typically paid on a per diem basis, work in short term agreements, and are considered a contractor versus a full-time salaried employee.
How is it billed?
Claims may be submitted for services rendered by a physician or physician therapist for covered visit services by appending modifier Q6 (Service furnished under a fee-for-time compensation arrangement by a substitute physician; or by a substitute physical therapist furnishing outpatient physical therapy services in a health professional shortage area, a medically underserved area, or a rural area Q6).[2] The information on the claim should represent the name and NPI of the physician/physical therapist who needed the substitute.
Did you know?
In 2021, the Department of Justice cracked down on telemarketers operating in conjunction with locum tenens companies under Operation Happy Clickers which resulted in losses in the tune of $7.3 million.[3] In early, 2020, two ophthalmologists were ordered to pay back almost $950,000 due to billing for a provider who was employed, but also was not credentialed to bill for Medicare.[4]
What to look for?
When evaluating and/or auditing claims submitted with modifier Q6, look for the following scenarios which would be considered inappropriate usage of modifier Q6:
1) Services billed longer than 60 days with modifier Q6
2) Providers fully employed in the same group
3) Filling in for a deceased provider
4) Ask for a log of patients seen by the substitute provider along with the dates of service
If you have any questions or comments, please reach out to [email protected].
References:
[1] https://www.palmettogba.com/palmetto/rr.nsf/DIDC/8EELHJ3576~Claims~Modifier%20Lookup
[2] https://www.aapc.com/codes/hcpcs-modifiers/Q6
[3] https://www.justice.gov/usao-wdmi/pr/2021_0824_Happy_Clickers
[4] https://www.justice.gov/usao-sdca/pr/san-diego-eye-doctors-pay-950000-settle-medicare-billing-fraud-allegations; https://www.cpmlegal.com/media/news/310_Jain%20Unsealed%20Complaint.p