As the number of COVID-19 cases continues to rise in the U.S., the fast spread of the virus is causing gaps in practice staffing, and patient influx will likely increase, leaving systems needing more providers. The use of locum tenens physicians can help practice fill gaps at your organization caused by COVID-19. Below we offer information on what you’ll want to consider when tapping this staffing solution.
Important note: Liability coverage options and licensure for locum tenens physicians vary by state, but licensing requirements have been relaxed under the Coronavirus Preparedness and Response Supplemental Appropriations Act (H.R. 6074), which temporarily loosens restrictions for practicing across state lines, including increased access to telemedicine.
In the U.S., locum tenens were first used in the 1970s, and demand for these temporary physicians has quietly escalated over the past 15 years. The number of U.S. physicians working as locum tenens—contracted physicians who substitute for physicians when they are vacationing, sick, attending conferences, on maternity leave or have left a practice—has steadily risen, from an estimated 26,000 physicians in 2002 to more than 56,000 physicians in the past few years. Utilizing locum tenens can be advantageous, but the rules must be followed to ensure proper reimbursement. The Centers for Medicare & Medicaid Services (CMS) allows payment for services provided by locum tenens, but practices need to follow the guidelines closely.
Identifying Locum Tenens
Locum tenens physicians don’t have to be enrolled in the Medicare program or be in the same specialty as the physician for whom they are covering, but they must have a National Provider Identifier (NPI) and possess an unrestricted license in the state in which they are practicing. A locum tenens physician cannot be used to cover expansion or growth in a practice. Medicare beneficiaries must seek to receive services from their regular physician, and services may not be provided by the locum tenens over a continuous period of more than 60 days (with the exception of a locum tenens filling in for a member of the armed forces called to active duty). Additionally:
- A practice can employ a locum tenens for only 60 days or less. Claims must be submitted under the absent physician’s NPI number and name, and the locum tenens physician is reimbursed by the practice.
- No extension can be granted for the 60-day maximum. If a physician will be out for more than 60 days, two alternatives exist:
- the practice may employ an additional locum tenens to take over, or
- the physician can return to work for a limited amount of time, which can be as little as one day. That restarts the 60-day time limit.
- The Q6 modifier must be placed in Box 24D on the HCFA 1500 form, signifying to Medicare that a locum tenens performed the service.
- The practice must keep on file a record of each service furnished by the locum tenens physician, with their NPI or Unique Provider Identification Number (UPIN).
In addition to maintaining the practice’s revenue stream, a locum tenens physician also ensures continuity of patient care. Patients can still see a physician within the practice setting without interruption, increasing their trust and willingness to work with the practice and making it less likely they’ll seek the care of another physician in your absence.
Note: Verify locum tenens policies with your state’s Medicaid office and commercial carriers; some may follow CMS policy, but others may require enrollment.
Plan Ahead for a Positive Experience
Physicians need to plan carefully when making the decision to have someone else represent their business. Some tips:
1. Cultivate staff buy-in & support
When vetting locum tenens physicians, remember it’s not only patients who will interact with the substitute provider, but also office staff. Look for the most qualified candidate and the best personality match for the practice’s work culture. If the office staff is not comfortable working with the locum tenens physician or doesn’t understand the process or guidelines, the practice won’t run as smoothly.
2. Research locum tenens organizations
Research locum tenens firms and get as much information as possible to alleviate concerns. Contact the National Association of Locum Tenens Organizations (NALTO) to research and review relevant data and materials. NALTO lists member organizations that provide locum tenens services, and all NALTO members are subject to the association’s code of ethics.
3. Interview locum tenens organizations
Contact organizations that seem to be a good match for your individual practice needs. Ask key questions, such as how they vet their physicians, and have them provide any background information. Determine how quickly a locum tenens physician can be placed if needed. Request information on the firm’s malpractice coverage, and ask the organization to provide a sample contract to review.
4. Check your existing malpractice coverage & any specific state requirements
Liability coverage options for locum tenens physicians vary by state and by the underwriting policies of individual carriers. Contact your medical professional liability insurance carrier to discuss coverage options before hiring a locum tenens physician. Let your carrier know what coverages the locum tenens firm offers or carries on its physicians.
5. Be clear about your expectations for a locum tenens provider
It is important to determine if an individual provider’s work habits, work hours/schedule and priorities match the normal operations of your practice. As candidates are interviewed, make sure expectations are spelled out and that there is an agreement from both parties regarding specific work requirements.
6. Consider a trial run
If possible, consider a short trial in advance of planned time off. Hiring a locum tenens for a shorter time frame allows providers an opportunity to work with the locum tenens firm and give the office staff a trial experience of working with a locum tenens physician. A trial run helps ensure the locum tenens firm and services meet the needs of the practice before making a commitment for a longer coverage period.
7. Avoid common misunderstandings
The locum tenens provision is widely used, but often misunderstood; this puts practices at risk. Many companies that place locum tenens are reputable and clearly understand CMS rules, but others may mislead practices into thinking they can keep locum tenens for the long term or use nurse practitioners as locum tenens. Section 1842(b)(6)(D) of the Social Security Act clarifies this is a physician for physician services provision. Services provided by non-physician practitioners (e.g., nurse practitioners and physician assistants) may not be billed under the locum tenens provision. Ultimately, it is the responsibility of the physician or group practice to know and follow locum tenens guidelines.
Contracting with locum tenens can be a mutually beneficial situation for both the practice and the locum tenens physicians. With proper research and vetting of locum tenens physicians, providers can take time away from the office while ensuring continuity of care and continuing to generate revenue for the practice’s bottom line.
For questions or additional information, contact the ACR practice management department at [email protected].
NOTE: Story updated April 27, 2020, to reflect new considerations under the COVID-19 emergency.