Businesses the nation over have been succumbing to temp-tation, employing staffing agencies as a means to appease their ongoing craving for cost-effective, short-term labor. And in an era when economic uncertainty is king, not even healthcare facilities are exempt from pursuing the temp.
Recent U.S. Department of Labor figures bore impressive news for staffing agency demand, citing a rise in the temp penetration rate to the highest level it has reached in more than 5 years. While the percentage of temps in the workforce still sits below past peak times and levels in other countries, the role of the locum tenens has carved out a significant niche for itself in office operations over the years.
Physicians touting a temporary payroll stub, while still largely infrequent, have done their time for primary care practices in a bind. Jon Osborne, vice president of research and editorial at Staffing Industry Analysts, noted in a Chicago Tribune interview that approximately 10 percent of the nation’s labor pool is comprised of temp-for-hire individuals, inclusive of physicians, dentists, CRNAs, physician assistants, nurse practitioners, administrative aids and allied health professionals.
Chris Varvares, a co-founder of Macroeconomic Advisers, told the Chicago Tribune that agencies pay their temp-employees anywhere from $10 an hour for industrial work or administrative tasks to $117 an hour for physician duties. Due to the fact that agencies are responsible for temp-employee benefits and documentation, Varvares and other agency analysts have noticed employers taking a less apprehensive stance when considering such staffers.
"Companies have discovered over time that having a layer of your labor force that is contingent is a good thing," Osborne said.
For example, Chicago — the fourth-largest location booming in the temp market — puts forth $200 million for healthcare-posted workers annually and $450 million for office/clerical workers, Osborne said. That demand is expected to expand, according to analysts, now that the job market has begun its resurrection.
Given the increasing popularity of this temporary alleviant to workforce woes, it’s important for physician practices considering temporary-hires to follow proper strategy to maximize their returns. Barton Associates (BA), the self-designated locum tenens experts, blogged about the temporary healthcare physician as being an investment — one that can be made in full confidence by adhering to the BA’s below billing guidance, categorized by scenario:
Placeholder for a physician returning within 60 days
In this situation the Medicare Claims Processing Manual allows you to bill for locum tenens professional fees using the absent physician’s billing information as long as the following conditions are met:
- The regular physician is unavailable to provide the visit services.
- The patient has arranged or seeks to receive the visit services from the regular physician.
- The locum tenens provider is paid for his/her services on a per diem or similar fee-for-time basis.
- The substitute physician does not provide services to Medicare patients over a continuous period of longer than 60 days.
If these conditions are met, you can bill for the locum’s professional services using the absent provider’s national provider number (NPI) in box 24 of the CMS-1500 form. You must also use modifier –Q6 (Service furnished by a locum tenens physician) in box 24d of the CMS-1500 form for each line item service on the claim to indicate the service was provided by a locum.
Placeholder for a physician returning after 60 days
If you find yourself in this situation, there are a few options for billing locum tenens coverage:
- Use a new locum after the first 60-day period has expired.
- Begin the Medicare enrollment process at the beginning of the assignment. Then, bill the services provided beyond the initial 60 days using the locum’s NPI number.
- Have the absent physician return to the practice for a short period of time to reset the 60-day clock. Then re-use the same locum.
The amount of time you have to prepare for the locum assignment will determine which option you will ultimately use. If you have more than 60 days before the locum would need to start working, you could enroll him or her in Medicare and bypass using the –Q6 modifier altogether. However, if you need to fill an immediate opening, option one or two is more appropriate. Option three is only appropriate if the absent physician is available to return for a short time.
Medicaid billing guidelines typically mirror Medicare rules; however, you may want to review your state’s requirements to be sure. Also Medicare and Medicaid rules are subject to change, so be sure to check with your Medicare Administrative Contractor with any billing related questions.
Staffing up to meet demand
In light of the physician shortage, clients are increasingly using locum tenens physicians as a key component of their long-term staffing strategy, to start new service lines, and to augment permanent staff while searching for a permanent doctor, which can be a lengthy process. Under these scenarios, locums are not covering for an absent physician who will be returning and therefore do not meet the requirements for using the –Q6 modifier. In these cases, Medicare and Medicaid require locum providers to enroll in the programs in order to receive reimbursement.
Many commercial payers require facilities to credential the locum tenens physician through the normal process and allow for retroactive billing. In most cases, it is best practice to submit credentialing and enrollment forms in advance of the locum’s first day on assignment.
Billing for locum tenens nurse practitioners
The CMS billing guidelines for locum tenens physicians do not apply to nurse practitioners. The directions for billing locum tenens nurse practitioner services differ from state to state. You should contact your local Medicare administrative contractor to find out if using modifier –Q6 is appropriate.
You must keep detailed records of all of the services provided by locum tenens physicians and NPs. Doing this will allow you to prove the services were rendered by the locum in case of an audit or malpractice suit. Facilities and practices that use an electronic medical records system can print the claims at any time, and therefore don’t need to keep a paper copy of the claim. They should, however, keep track of the dates that locum tenens providers were used so they can easily access claims.
Read more from the Barton Associates blog post here.