Locum Tenens – Has a New Name

Two doctors shaking hands

CMS now refers to Locum Tenens as Fee-for-Time Compensation arrangements. However, the regulations remain unchanged. These arrangements are used by substitute physicians for various reasons, such as maternity leave, prolonged illness, education, and vacation.

CMS specifies that “physicians” make use of these arrangements. Medicare guidelines state that “services provided by non-physician practitioners (for example, CRNAs, NPs, and PAs) cannot be billed under fee-for-time compensation arrangements or reciprocal billing reassignment exceptions.”

An exception exists for physical therapists who provide outpatient physical therapy services in rural areas designated as Health Professional Shortage Areas (HPSA) or Medically Underserved Areas (MUA).

According to section 16006 of the 21st Century Cures Act, a Medicare-enrolled physical therapist is permitted to employ a substitute physical therapist to provide outpatient physical therapy services in a Health Professional Shortage Area (HPSA), a Medically Underserved Area (MUA), or a rural area under a fee-for-time compensation arrangement starting on or after June 13, 2017.

A regular physician or physical therapist is the physician or physical therapist who is
normally scheduled to see a patient. A regular physician may include a physician specialist (such as a cardiologist, oncologist, urologist, hospitalist, etc.).

The criteria for fee-for-time arrangements include:

  • The regular physician or physical therapist must be unavailable to provide the services;
  • The Medicare beneficiary has arranged or is seeking to receive the services from the regular physician or physical therapist;
  • The regular physician or physical therapist compensates the substitute on a per diem or similar fee-for-time basis;
  • The substitute physician or physical therapist may not provide services to Medicare patients for a continuous period exceeding 60 days, with an exception for those called to active duty in the Armed Forces who may exceed this limit; and
  • The regular physician or physical therapist must indicate that the services were provided by a substitute under a fee-for-time arrangement by entering HCPCS code modifier Q6 after the procedure code, denoting services furnished by a substitute physician or physical therapist in a health professional shortage area, a medically underserved area, or a rural area.

According to Novitas-Solutions JH, “A physician or physical therapist may have reciprocal billing arrangements with more than one physician or physical therapist. The arrangements do not need to be in writing.”

This is a fairly complex arrangement. For more information, see our resources cited below.

If you or your group would like more information on fee-for-time compensation arrangements, please reach out to [email protected] or [email protected].

LocumStory webpage

CMS CPM:  30.2.11 – Payment Under Fee-For-Time Compensation Arrangements
(formerly referred to as Locum Tenens Arrangements) – Claims Submitted
to A/B MACs Part B

Noridian (NPP PAGE) – https://med.noridianmedicare.com/web/jfb/specialties/nonphysician-practitioners

Palmetto:  https://www.palmettogba.com/palmetto/jjb.nsf/DID/1N9J09DXTU

Novitas: Reciprocal or Fee-for-Time Compensation Arrangements