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Hiring locum tenens providers can be a highly effective way to maintain patient access and continuity of care—but without a clear billing strategy, it’s easy to lose revenue or risk compliance issues. From Medicare regulations to private payer policies, navigating locum tenens billing requires a working knowledge of provider classification, documentation standards, and enrollment requirements.
This guide outlines key billing distinctions, best practices, and compliance tips to help healthcare leaders bill accurately and optimize reimbursement when using locum tenens coverage.
Billing for locum tenens services starts with determining how the provider will function within your facility: as a replacement physician or a supplemental provider.
This applies when a locum tenens physician is filling in for a regular, credentialed provider who is temporarily unavailable—for example, due to vacation, illness, or a short leave of absence. Under Medicare guidelines, you may bill for this type of coverage using HCPCS modifier Q6, and services must be provided for no more than 60 continuous days.
Important: The regular physician must be expected to return, and the locum cannot stay beyond 60 days unless under exceptions like military deployment or maternity leave.
If the locum tenens provider is augmenting your existing staff—such as supporting growth or covering an unfilled position for more than 60 days—they are classified as a supplemental provider. In this case, the standard provider enrollment process applies, and Q6 cannot be used. This includes completing Medicare Form 855R and securing enrollment with major payers.
When billing Medicare for services delivered by a replacement locum tenens provider, modifier Q6 should be appended to the procedure code (e.g., on CMS-1500 form, box 24D).
To use Q6 appropriately:
Failure to meet these criteria can result in denied claims or compliance concerns.
Medicare separates locum tenens billing into two categories:
Allows billing under the absent physician’s NPI with Q6 for up to 60 days.
Covers physicians with a contractual agreement to work alongside current staff. These providers must be fully enrolled with Medicare and private payers.
In both cases, the billing entity and the provider share responsibility for overpayments and compliance with claims access.
While many commercial payers and Medicaid programs follow Medicare’s lead, policies differ by state and carrier. Healthcare leaders should:
Aligning billing practices with each payer’s expectations ensures claims are accepted and cash flow is protected.
To avoid delays, denials, or audits, ensure the following processes are in place:
Maintain clear records of the locum’s start and end dates, coverage duration, services performed, and any contractual agreements.
Flag the locum’s coverage period in your scheduling and billing systems. Assign reminders to monitor the 60-day limit if Q6 is used.
Partner with your locum tenens staffing agency to expedite credentialing and licensing. For supplemental roles, begin enrollment with major payers as early as possible.
Double-check CPT codes, modifiers, NPIs, and dates of service before submitting claims. Mismatches in documentation and billing are a top cause of delays.
Analyze locum-related claims separately within your revenue cycle reports. Look for recurring issues tied to documentation, denial trends, or payer-specific errors.
A small oversight in classification or modifier use can delay payments or trigger recoupments during audits.
Locum tenens staffing isn’t just about coverage—it’s about protecting patient access and preserving revenue. By properly classifying providers, aligning with payer requirements, and following Medicare rules, your organization can ensure timely reimbursement and minimize risk.
Need support managing locum tenens billing or coverage planning? Partner with Caliber for strategic staffing solutions built on compliance, flexibility, and operational performance.
