We are hiring a part-time/per diem radiologist who has been working with us as a per diem contracted locum. While working for us, we used the q6 modifier to identify them as locum coverage. Their coverage has been sporadic and we have not used their 60 day allotted periods.
We have begun the process to credential the provider with payors, we all know how long Medicare can take to complete this... We are being told that once we submit an application to Medicare that we may no longer bill them as locum. As we understand this, Medicare has this policy to avoid providers from using this modifier as a crutch to cover for "mistimed credentialing," but does this really mean we can no longer use the locum until they are credentialed? Or if we use them we cannot bill for their services? Is there an exception or another way to bill for their services during this time?
<u5:p>This is what was quoted</u5:p><u5:p> - </u5:p>A physician in the process of being credentialed does not meet the definition of a "substitute physician" whose services can be billed under the fee-for-time compensation arrangements guidance. See Medicare Claims Processing Manual Chapter 1, Sec. 30.2.11 - Payment Under Fee-For-Time Compensation Arrangements (formerly referred to as Locum Tenens Arrangements). If the MAC has information that connects the physician being credentialed with the practice, that physician is not a substitute physician.
<u5:p> </u5:p>Also, note that Subsection C indicates that the substitute physician or physical therapist may not have reassigned his or her right to Medicare payment to the group through a CMS-855R reassignment enrollment which is part of the credentialing process. Reassignment is a routine part of the credentialing process."<u5:p></u5:p>
Thank you in advance for any assistance on this. Kevin
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Kevin Ordway
Executive Director
Radiologic Associates of Middletown, Middletown CT
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