Summary
Groups don’t always understand the requirements of the locum tenens arrangement. Who can be a locum? How long can their services be used? In what way can we utilize them? These are questions we hope to answer for our readers in today’s article.
March 16, 2020
“Lawd, I was born a ramblin’ man. Trying to make a living and doing the best I can. But when it’s time for leaving, I hope you understand that I was born a ramblin’ man.” Those lyrics from the legendary Allman Brothers Band provide a wistful backdrop and pensive introduction to our subject for today. They closely capture the image the government intended us to have when it comes to the locum tenens doctor—a man or woman who goes from facility to facility and from town to town providing temporary services, and then moves on again.
What is surprising about these medical guns-for-hire is that they are so misunderstood by many in the healthcare industry. That is, many who work in the medical field and who wish to engage these itinerant practitioners are often unclear about the rules governing their services. With that in mind, let us take a closer look at how groups can appropriately utilize the locum tenens provider.
What’s in a Name?
In attempting to better understand the rules surrounding locum tenens services, it may be helpful to first define the term. Locum tenens is a Latin phrase that essentially carries the idea of holding the place of someone else. You’re at Disneyworld, waiting in a long line, and you have to leave momentarily. You ask a bystander if they can hold your place for you until you return. That’s the idea of the locum tenens provider. You, as a group provider, must leave for a period of time. Someone needs to be made available as a place holder, someone who can take your cases and see your patients so that the group continues to operate in an optimal fashion until your return.
Given the intention of the locum tenens arrangement, let us stipulate a couple of core points:
- The locum, if I may abbreviate, is not meant to be a permanent addition to the group. If you’re looking to add another provider to the group, you need to hire and credential an individual who is not currently being used as your locum.
- Loc*ms should not be used to augment your existing workforce, where no provider is actually being replaced. That is, you cannot use them to fill weekend or evening coverage in the name of group doctors who are normally scheduled to be off during those times.
Certain Medicare sources have made the above points very clear, pointing out that the whole purpose of bringing in a locum is to temporarily replace a group doctor who is on vacation, or sick, or on maternity leave, or on sabbatical, etc.
Is There a Doctor in the House?
One of the oddities of the locum tenens arrangement is that the locum physician is performing services in the name of the absent group member. So, when the claim goes out reflecting the locum’s services, it goes out under the NPI of the physician for whom the locum is filling in, along with a Q6 modifier in most cases (some carriers do not accept this locum identifier).
This brings up a key point. From time to time, we will have groups ask us about a using a CRNA as a locum. While you can certainly bring in an anesthetist on a temporary contract basis, you would not be able to bill that CRNA’s services in the name and NPI of anyone in your group. A locum tenens provider is always a physician who is always replacing another physician (though CMS has made a recent exception for physical therapists). There is no such thing as a “locum CRNA.” If you do bring in an anesthetist on a temporary contract basis, you will have to get them linked to the group/payers in order to bill for their services; and, when such services are submitted, they will be submitted in the name and NPI of that contracted CRNA.
T Minus 60
No locum can be used for more than 60 consecutive calendar days. The clock starts on the date when the locum first provides services and ends essentially two months later, whether the locum worked only 5 of those days or all 60. At the conclusion of the 60 days, the group has two options should they need physician services beyond this time:
- The absent provider returns to work for at least one day. Upon leaving again, this would restart the clock for the locum tenens doctor.
- Hire or contract with another doctor. While your locum is providing services, you can use this time to identify, recruit and begin the credentialing process of a new physician.
There is no getting around the 60-day rule, unless the absent doctor is gone due to military service (e.g., reserve call-up). In that event, there is a specific exception.
Gone for Good
Clients will often contact us about solutions for a doctor who has permanently left the group. Perhaps they retired or moved away or started their own practice. When this happens, the group is often left scrambling to replace that physician. If you had a heads up on the doctor’s departure, you may have had enough time to recruit a permanent replacement and begin the credentialing process. However, there are times when a group does not have advance warning. Perhaps the group member suddenly died or quit without sufficient notice. In such a scenario, you need quick options. Entering into a locum tenens arrangement is indeed an option in such circ*mstances. Even though an anesthesiologist has permanently left your group, you can still bill out a locum’s services under the name and NPI of the departed doctor—as long as you meet the following stipulations:
- Abide by the 60-day rule. You cannot retain the locum ad infinitum until a replacement is found. Again, you should utilize these two months to find and credential a permanent replacement.
- Attorneys recommend that you obtain the permission of the group member who has permanently left before billing out locum services in their name and number, where possible.
On the Road Again
Hopefully, this article has helped to clarify for our readers the rules regarding this nomadic band of anesthesia providers. Remember, for anesthesia, the term “locum” only applies to anesthesiologists, not CRNAs. As long as you undertake measures to reimburse the locum tenens anesthesiologist for the services he or she performs on behalf and in the name of the absent group member (often a per diem payment), and keep on file a record of each such service (required by CMS), you will be able to take advantage of this unique arrangement and thereby fill a vital need—at least on a temporary basis. Remember, after 60 days, your locum will need to hit the road once more.
If you still have questions concerning this topic or wish to discuss how to best utilize loc*ms in your practice, please reach out to your account executive or email us at [email protected].
With best wishes,
Tony Mira
President and CEO
