January 8, 2016

Yesterday we discussed if a doctor hires an independent contractor physician or a locum tenen physician whether you can bill insurance companies as a billing provider and put their name as service provider. 

I received the following appreciated and helpful additional comments - 


Hi Jennifer:

Here’s some additional locum tenens info:
Medicare requires claims for services provided by a locum tenens physician to include the Q6 modifier, which designates services were performed by a locum tenens physician, in box 24D of the CMS-1500 form. The regular physician’s provider identification number goes in box 24J.
Happy new year to you and family.
Marty Kotlar, DC, CBCS, CPCO
President, Target Coding


Jennifer – Your reply statements are correct and questions appropriate. 

Independent Contractor:
Under this arrangement the independent contractor must be linked to the practice TIN# in order for the practice to be paid.  If independent contractor and the existing practice are both in or both out of network – simpler process.  If one is in network and one is out of network  - not so simple.   

Locum Tenens (Medicare Standard):
A substitute physician takes over the professional practice when the regular physician is absent for reasons such as illness, pregnancy, vacation, continuing medical education and the regular physician bills and receives payment for the substitute physician’s services as though he/she performed them.  In this case the substitute physician does not have to be enrolled in the Medicare program.

Important -  The locum tenens rule is a Medicare rule, and is applicable to Medicare and for physician services only. Be cautious when applying this concept to commercial payers. First, determine if the commercial payer being billed has adopted the Medicare locum tenens rule. In many commercial carrier cases where the service is performed by a non-credentialed physician—even a locum— it is not compensable. 

Knowing the rules to carry out either process is important to achieve success.

Alisa Rivera, VP Operations
? Direct: 845-363-4845 |? Fax: 845-278-9022
1620 Route 22 – Brewster, NY 10509    


Hi Jennifer,
I hope your 2016 is off to a great start!  
For locum tenens billing, our understanding is that no credentialing is needed because the locums is providing coverage for the provider temporarily (only for the vacation time).  Billing is done with the provider’s name, appending a Q6 modifier to the CPT code (charge).  The Q6 modifier designates that the service was performed by the locums.
Thank you for all the information that you provide us in your ongoing newsletters!
Tia Payne, Senior Systems Administrator
Physician Revenue Navigators
P: 775-323-5135 ext 3110


Hi Jennifer,

Happy New Year! Thank you for your newsletters! We love them! As for IC and/or Locums being billed under the billing provider it is widely accepted, however, as you indicated every Payor has its own guidelines. For example: GHI/EmblemHealth or BCBS do not allow a non-boarded physician to see patients. So, there is a process when a new physician needs to be added/linked to the group and has to meet certain criteria (Board Certification is one of them). Aetna requires service providers to be MDs in order to bill under the MD, otherwise reimbursements are cut by 20-25%. The list goes on...

Hope that helps.



Manhattan Billing & Collections, Inc.
(866) 777-1505


Hi Jennifer,
First and foremost, the locum tenens rule is a Medicare rule, and is applicable to Medicare physician services only. Providers should always check with their commercial payers since not all commercial payers have adopted the Medicare locum tenens rule. There are many commercial payers that do not recognize the locum tenens rule and if a service
is performed by a non-credentialed physician, it would not be compensated as an “in-network” service.
For Medicare, the locum does NOT have to be a participating provider. Access the below link for the complete CMS Locum Tenens rule:
Theresa Wilson CMRS, CMBP
Practice Synergy, LLC
862-210-8008 x101
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Have a question or comment for Jennifer?
Contact Jennifer at Jennifer@Kirschenbaumesq.com or  at (516) 747-6700 x. 302.