Navigating Guidelines: Locum Tenens Providers

In the dynamic and ever-evolving field of healthcare, the role of anesthesia locum tenens providers has gained significant prominence.  Understanding how to navigate locum tenens provider guidelines is critical in coding correctly for services. One of the primary reasons for the increasing demand for anesthesia locum tenens providers is the ongoing shortage of anesthesia professionals in many regions. These providers can step in quickly to fill gaps in staffing, ensuring that surgeries and medical procedures can proceed without delays.

We have received a lot of calls and questions over the past few months regarding locums and wanted to reiterate the guidelines and rules around compliantly billing for locum providers. 

In order to understand anesthesia locum tenens providers we must define them. 

1. First, locum tenens billing is applicable to physician billing only and does not cover CRNAs.
2. The term “locum CRNA” should not be used as it can cause confusion. Payers do not acknowledge the term.  
3. Groups must enroll the CRNA and bill that CRNA under their own provider number, groups cannot use a ‘substitute’ number or name.

Locum providers are physicians.  They are typically seasoned professionals with a wealth of experience.  Anesthesia locum providers are often subject to rigorous credentialing processes, ensuring that only qualified individuals are allowed to provide anesthesia services. This commitment to quality assurance benefits patients and healthcare facilities alike.  When considering Medicare rules, there are three scenarios in which the locum tenens may fulfill a role within an anesthesia practice, each with billing challenges.  

1. Coverage for an absent anesthesiologist

• Medicare can be billed for the locum tenens services under the absent anesthesiologist’s NPI number.
  • This arrangement cannot exceed 60 calendar days.
    • If the absent anesthesiologist returns to work within 60 days and needs to enter a new period of absence the same locum tenens may begin a new period, again not to exceed 60 days.
    • If the absent anesthesiologist cannot return to their position before the end of 60 days, the locum must be credentialed and hired as would occur for a new anesthesiologist.  
    • Locum tenens can “replace” an employed physician for up to a continuous 60-day period unless the physician is called to active military duty in which the time period is unlimited.
  • The locum tenens will be compensated on a per diem or similar rate.  
  • A record of each service provided by the locum tenens must be maintained, to include the locum tenens NPI number.

2. Coverage for a practice anesthesiologist vacancy:

• Medicare can be billed for the locum tenens services under the vacating anesthesiologist’s NPI number.
  • This arrangement cannot exceed 60 calendar days (unless a vacancy was created due to the active military duty of the original anesthesiologist).  
  • The locum tenens will be compensated on a per diem or similar rate.  
  • A record of each service provided by the locum tenens must be maintained, to include the locum tenens NPI number.

3. Coverage for practice growth or peak demand:

• As the locum tenens will not be replacing an anesthesiologist, the locum tenens will need to be introduced to the practice by following normal credentialing and enrollment.
  • This should be completed timely, prior to the start of the locum tenens first day with the practice to ensure there is no delay in processing.  

Credentialing and Billing: 

• The process of credentialing locum providers must be done. 
• Healthcare institutions must ensure that these professionals meet all necessary licensing and regulatory requirements.  
• *Groups should check their individual payer contracts for any specific guidelines and their state policies.    
• The Q6 modifier will go out on the provider claim.  
• Groups should track dates when they started billing the modifier and keep detailed records of all services.  

* Note that while the details provided are based on Medicare guidance, Medicaids typically follow these rules.  Many commercial payers may also adopt these criteria or implement their own policies for billing locum tenens services.  It is important to evaluate the payer mix for each group to understand any potential challenges prior to beginning a locum tenens service. 

ACE knows that staffing is hard right now.  We are here to assist with any questions you may have.  Please reach out to us at aceadmin@aceauditors.com, and we can set up a call with one of our experts! 

Click here for the CMS Claims Processing Manual to review section 30.2.11.