Locum Tenens vs. Temporary Staffing: The Rules for Billing, Credentialing

Locum tenens is a Latin phrase that translates to “placeholder” and can refer to anyone who fulfills the duties of another on a temporary basis. In healthcare, locum tenens refers to a substitute provider hired to take over a provider’s professional practice when they're absent or on leave (e.g., an illness, vacation, pregnancy leave, or continuing medical education sabbatical). The colloquial term for these professionals, whether used in the singular or plural, is "locums."

For patients, the locum tenens provider performs the same services as the regular physician or other clinician. But there are differences when it comes to credentialing and billing for these distinct categories of providers.

What's the difference between a locum tenens provider and a temporary staffer?

By definition, a true locum tenens provider can only fill in for a colleague for a total of 60 consecutive days. By contrast, temporary staff may work longer than 60 consecutive days in the position and are subject to different credentialing and billing requirements.

While the two terms are commonly co-mingled, when it comes to medical billing under federal guidelines, these two types of providers are very different. As a result, when sourcing providers from locum tenens firms, it is crucial to understand the difference.

Characteristics of and requirements for a locum tenens provider

The following are distinguishing characteristics of "locums" and of the circumstances that make them a necessity in healthcare:

  1. The locum tenens provider is typically a traveling clinician. They often don't have a practice of their own and contract with an agency or multiple agencies for placements within a geographic area or nationwide as needed.
  2. The unavailability of the regular provider is not due to the physician having the day off or other regularly scheduled time off, or due to a staff shortage.
  3. The locum tenens services for patients of the regular physician are not restricted to the regular provider’s office.
  4. The Medicare beneficiary (patient) has arranged or seeks to receive the visit services from the regular provider.
  5. The substitute provider does not provide the visit services to Medicare patients over a continuous period of longer than 60 days.

Billing, documentation, and reimbursement guidance for a locum tenens provider

There are stringent billing guidelines health systems must follow if a clinician is billing as a true locum tenens provider. When the billing department remits for payment, it will send the claim out in the regular provider’s name with the appropriate modifier to indicate that a locum tenens provider is filling in. Typical guidelines for payment of locum tenens providers follows:

  1. The regular provider bills and receives payment for the services of the substitute as though they performed the services.
  2. The regular provider pays the locum tenens professional (or the agency that placed them) a fixed amount per day, with the substitute having the status as any independent contractor, rather than an employee.
  3. The regular provider identifies the services as substitute services that meet the requirements of the section by appending the code modifier to the procedure code.
  4. The regular provider keeps a record of each service provided by the substitute associated with the substitute’s National Provider Identifier, and makes this record available to the Medicare carrier upon request.
  5. Substitution services for post-operative follow-up care furnished during the period covered in the global fee should not be identified on a claim as substitution service.
  6. Medical group claims, per diem, or fee-for-time compensation that the healthcare organization pays the locum tenens provider are considered paid by the regular provider—who must be a member of the group (and the same requirements above must have been met).
  7. If the circumstance of the locum tenens provider's employment do not meet the above guidelines, they will be required to undergo the host organization's credentialing process and must bill under their own provider number when filling in for the regular provider.
  8. For medical group locum tenens billing, a temporary replacement may be considered a member of the group until a permanent replacement is obtained when a physician leaves a group practice. This is allowed as long as the replacement does not provide services to Medicare patients over a continuous period of longer than 60 days.

Locum tenens providers offer health systems and group medical practices a flexible way to fill positions temporarily when their regular providers are on leave. But it's essential for host organizations—and the providers themselves—to understand the requirements for these fill-in professionals. It’s also important to follow the billing guidelines for locum tenens providers to maximize reimbursements, avoid payment delays, and avoid compliance risks.

Explore symplr's credentials verification services to assist with your organization's temporary staff needs for credentialing, payer enrollment, licensure applications, and more.

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