Wait for service: Locum tenens is not the answer for unenrolled doctors

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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 premium article discusses Medicare fee-for-time compensation arrangements, often referred to as locum tenens, in the context of physician hiring and enrollment timing. It is aimed at coders, practice managers, compliance staff, and billing professionals who need to understand the general framework for substitute-provider billing, the role of enrollment, and the risks highlighted by a fraud settlement and agency guidance.

Why This Topic Matters

Improper use of substitute-provider billing can create compliance exposure for practices, especially when a new physician is not yet enrolled. The article helps readers recognize that enrollment timing, payer guidance, and billing oversight can affect how services are billed during staffing transitions.

Article Sections

  1. Enrollment

    Introduces the scenario of a newly hired physician whose enrollment is still pending and frames the billing concern around substitute-provider arrangements. It also references general Medicare guidance and a payer FAQ related to those arrangements.

  2. Alleged locum tenens violations

    Summarizes a Department of Justice settlement involving billing allegations tied to physician credentialing and provider identity. The section provides a compliance context for why misuse of substitute-provider billing may draw enforcement attention.

  3. Wait on enrollment

    Closes with practical guidance focused on the importance of timely enrollment support and awareness of Medicare billing timing considerations. It reinforces the article’s compliance theme without giving detailed coding instructions.

What You Will Learn

  • How Medicare fee-for-time compensation arrangements are framed in the context of physician staffing changes
  • Why enrollment timing matters when a new physician joins a practice
  • What types of compliance risks can arise when substitute-provider billing is applied incorrectly
  • How agency guidance and enforcement actions can inform billing oversight
  • General considerations for coordinating hiring, enrollment, and claims submission

Who Should Read This

  • Medical coders
  • Billing staff
  • Practice managers
  • Compliance professionals
  • Physician group administrators

Codes Discussed

Modifiers Discussed


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