Don’t get too creative with 60-day locum tenens limit

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article discusses Medicare locum tenens policy as it applies to physician staffing gaps, temporary substitutions, and extended absences in medical practices. It is aimed at physicians, practice managers, billing staff, and coding/compliance professionals who need to understand the policy framework, CMS clarification, and administrative considerations involved in locum-based billing arrangements. The piece focuses on general guidance, common practice scenarios, carrier/MAC oversight concerns, and references to the Medicare Claims Processing Manual.

Why This Topic Matters

Locum tenens arrangements can affect how services are billed, who may be paid under a practice’s arrangement, and whether a practice stays within Medicare policy expectations. Understanding the scope of the rule helps practices avoid compliance risk when staffing gaps last longer than expected.

Article Sections

  1. Locum tenens use in Medicare practices

    Introduces why practices rely on temporary physician substitution during absences or staffing changes. It frames the policy issue in the context of Medicare enrollment and practice coverage needs.

  2. CMS clarification on the 60-day limit

    Summarizes the reported CMS clarification regarding the duration of substitute coverage and the need for attention to how long a temporary arrangement continues. The section also notes compliance and audit concerns raised by billing consultants.

  3. Alternative approach: credentialing the locum

    Describes an alternate administrative approach for practices anticipating longer-term coverage needs. It outlines the kinds of practice and enrollment considerations associated with using a credentialed physician.

  4. Official resources

    Lists referenced CMS and DecisionHealth resources for readers seeking the source materials and related educational content.

  5. CMS Q&As: Locum time limit; using locum to replace a departed physician

    Presents CMS questions and answers addressing extended absence scenarios and a physician leaving a group practice. It provides policy clarification and administrative context for locum billing arrangements.

  6. Quick review of Medicare's locum rules

    Reviews the main policy points excerpted from the Medicare manual, along with form and recordkeeping references used in locum billing workflows.

What You Will Learn

  • How Medicare locum tenens policy is described in practice settings
  • What CMS clarified about extended substitute-physician coverage
  • Which administrative alternatives practices may consider for longer coverage needs
  • What kinds of compliance and audit issues are associated with extended locum arrangements
  • Which CMS manual and billing form references are tied to locum tenens processes

Who Should Read This

  • Physician practices
  • Practice managers
  • Medical coders
  • Billing staff
  • Compliance professionals
  • Interventional practices

Codes Discussed

Modifiers Discussed


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