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Are You Billing Locum Tenens Under The Q6 Modifier?
Misinformation continues to surround the use of the Q6 modifier, or the billing for services provided by a locum tenens physician, resulting in mistakes that prove costly or even detrimental to practices, as they may result in audits or further disciplinary action.
The Q6 modifier is a tool that practices can use when a physician is away for an extended period of time, requiring temporary coverage by a locum tenens. It covers Part B fees or medical claims related to the professional service provided, billed using the existing physician’s NPI number, and the Q6 modifier.
To prevent abuse, there are stringent rules in place surrounding the conditions for using this modifier. When being used, the surrounding circumstances must be well-documented. Carefully review the details of when and how to use the Q6 modifier to ensure that you remain compliant.
When Can You Use the Q6 Modifier?
When the primary physician is unable to provide regular services to their patients and a locum tenens physician is called in. The circumstances that may prompt such leave are broad, and may include: illness, pregnancy, vacation, CME participation, bereavement, and so forth.
However, other conditions must be in place for the use of the Q6 modifier.
The Q6 modifier allows for a maximum billing of sixty (60) consecutive days. The only exception to this is when the regular physician is on active military duty. In this case, the restriction is waived, and the Q6 modifier can be used for a more extended period of time. After sixty billed days, the Q6 modifier can no longer be used to pay for locum tenens services for that physician’s absence. Additionally, you can’t use another physician to extend coverage at the end of 60 days, and the existing physician cannot have been gone for more than ninety (90) days.
The locum tenens physician must be paid per day, although this may be done directly or through an agency. They cannot be self-employed or working for another practice, and they must be a physician — not a nurse practitioner, physician assistant, or any other occupation.
What to Do If You Can’t Use the Q6 modifier
What happens if you need to extend coverage past 60 days or the primary physician chooses not to return? For example, a permanent physician may be using FMLA leave, taking 90 days off from work, or deciding to take another job while on leave. In either case, the temporary physician is no longer considered a true locum tenens after 60 days, and services can’t be billed under the Q6 modifier. Instead, the temporary physician must be enrolled with payers, and services should be billed under an individual NPI number. The physician is now considered an interim provider, as he or she is now filing a vacancy rather than providing replacement coverage.
It’s best to begin the payer enrollment process during the initial 60 days. This helps you avoid gaps in coverage and any compliance issues for using the primary physician’s NPI number past the allowed time.
How Do You Code For a Locum Tenens Physician?
There are two critical steps associated with using the Q6 modifier, in order to accurately note that another physician is filling in for the regular physician:
1. Add the Q6 modifier in box 24 D after the CPT/HCPCS code.
2. Note the regular physician’s NPI number in box 24 J.
Always check with the insurance carrier, as they may have guidelines in addition to the ones listed above. This is true for Medicaid and Medicare, as well as privately contracted plans.
Best practice is to create a protocol for your staff to use the Q6 modifier and retain the necessary documentation in case of an audit. It’s best not to leave any room for misunderstanding of these instructions.
It is essential to follow the rules associated with the Q6 modifier, respecting both the terms for its use while ensuring that the appropriate documentation measures are taken. Lack of compliance can result in errors that might put your practice in jeopardy of an audit or take-back.
The guidelines and instructions provided here are intended to help get you on track to using the Q6 modifier while remaining compliant. For detailed information on submitting claims for locum tenens physicians, check out the Centers for Medicare & Medicaid Services (CMS) Manual System.
Contact VISTA today to understand more about the Q6 modifier and how we can help with your locum tenens needs.
Editor’s note: This post was originally published December 13, 2018, and has been updated for accuracy and timeliness.