Compliance: Locum tenens is not the answer for unenrolled doctors

Why This Topic Matters

Improper billing under fee-for-time arrangements can create compliance risk, repayment exposure, and fraud allegations. The article helps readers recognize that temporary substitute billing rules are narrow and that new physician enrollment must be handled separately.

Article Sections

1. Medicare fee-for-time rules and temporary coverage

   Introduces the general Medicare framework for substitute physician coverage and the administrative context in which these claims are submitted. It also references Medicare manual guidance relevant to the topic.

2. Guidance on new hires and group expansion

   Summarizes contractor FAQ guidance addressing whether temporary substitute billing applies when a practice is expanding rather than replacing an absent physician. The section focuses on the distinction between temporary absence and adding new physicians.

3. Alleged locum tenens violations

   Describes a reported enforcement matter involving claims submitted for services furnished by an improperly credentialed physician and allegations about misidentified treating physicians. It places the case in the broader compliance context.

4. Wait on enrollment

   Offers operational advice for practices managing new-physician onboarding and emphasizes the importance of enrollment timing and billing readiness. The section also mentions retrospective billing considerations.