Locum tenens

Good afternoon.

After reviewing Locum Tenens fact sheet and WPS processing manual, I am still not sure of the proper use/billing when one of our physicians is deceased. The physician was an employee of our company. Management has made arrangements for a locum tenens, which will be greater than 60 days. Has anyone had any experience with this or any guidance on how we should bill for the locum tenens charges? Thank you in advance.


  • Just my opinion: Medicare would expect a decision to be made by the practice to replace the physician who is deceased. You would hire the locum to cover immediately, and during the 60 day window of time, you would hopefully have a new physician to start by the end of the 60 days. Use the newly hired physician's start date in the PECOS application and nearly every time they will approve a provider number and participation for the requested date. It can take up to 120 days to come to fruition but claims can be on hold until the number is created and appended to your group number.

  • Hello,
    Thanks for your question. From my reading of a few other MACs' guidance, the issue boils down to the fact that a locum isn't an option because the practice can't use the deceased provider's NPI/PTAN to report the locum's services.
    (Regarding the 60-day limit, the only exception is the active duty exception. However that doesn't apply here.)

  • From a Part B News story on the subject:

    "Intention is also important, says [Jennifer] Searfoss. What about extended leave? What if the provider is taking an indefinite amount of time to get over a personal tragedy, for example, or to decide whether she’s even interested in medicine anymore?

    "'Locum tenens literally means "in the place of,"' says Searfoss. 'Think of it like scab football players during a strike.' The original players are still on the roster — they just aren’t playing at the moment.

    "'So under the locum tenens concept, the doctor is supposed to be coming back,' she says..."


    Long story short: For Medicare at least, locum can't be used to fill in for deceased providers.

    BTW Jennifer Searfoss is doing a Locum Tenens webinar in July -- we'll have an announcement for it in upcoming issues. She knows everything about it, so if you ever use locum tenens it'll be worth your time.

  • Thank you all. This is very helpful.

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