Locum Tenens and temporary healthcare providers play a critical role in filling coverage gaps for independent practices. Whether a solo physician is taking time off, or a practice needs extra coverage during peak demand, locum and temporary clinicians ensure continuity of patient care.

But One of the Most Common Questions is: How Can Temporary Providers Bill for their Services under an Established Practice?

The answer depends on payer rules, credentialing status, and compliance requirements. Below, we break down how locum tenens and temporary providers can bill correctly, while helping independent practice owners maintain revenue flow and stay compliant.

1. Billing When the Temporary Provider Is Credentialed

If the locum or temporary provider is individually credentialed with payers and linked to the practice’s Tax ID (Group NPI/Type 2):

• Rendering Provider: The locum/temporary provider’s personal Type 1 NPI.
• Billing/Pay-to Provider: The practice’s Tax ID and Type 2 NPI.
• Payment: Goes directly to the practice, not the individual.

This is the cleanest and most compliant method, but credentialing can take 60–120 days depending on the payer.

2. Medicare’s Locum Tenens / Substitute Physician Rule (Q6 Modifier)

For physicians only, Medicare allows a locum tenens/substitute provider to bill under the regular physician’s NPI using modifier Q6.

• Coverage Duration: Up to 60 continuous days (extended for military leave).
• Claim Format: Billed under the absent physician’s NPI with modifier Q6 appended.
• Payment: Sent to the practice, not the locum.

Important: This rule applies to physicians only, not nurse practitioners or physician assistants.

3. “Incident-To” Billing for NPs and PAs

In physician-owned practices, incident-to billing allows NPs and PAs to bill under the supervising physician’s NPI, reimbursed at the physician rate.

Requirements:

• Patient must be established, with a treatment plan initiated by the physician.
• Physician must provide direct supervision (present in the office suite).
• Not allowed for new patients or new medical problems.
• Limited in facility settings (e.g., hospitals).

Misuse of incident-to billing is a common compliance risk, documentation must clearly support supervision and plan of care.

4. When the Provider Is Not Credentialed and Exceptions Don’t Apply

If a temporary provider is not credentialed and the payer does not allow Q6 or incident-to billing:

• Claims cannot be submitted under another provider’s NPI.
• The practice may have to absorb the cost until credentialing is completed.
• Submitting claims under the wrong NPI is considered fraudulent billing.

5. Compliance Best Practices for Independent Practice Owners

To protect revenue and minimize risk, practice owners should:

• Confirm payer rules in advance (Medicare, Medicaid, commercial plans vary).
• Use Q6 and incident-to billing only when criteria are fully met.
• Maintain detailed documentation of services, supervision, and coverage arrangements.
• Contract with temporary providers as independent contractors or locums, ensuring compensation is based on hours, shifts, or revenue share, not direct insurance payments.

Conclusion: Partnering for Success

Locum tenens and temporary providers are essential for keeping independent practices running smoothly during provider absences or seasonal demand. Billing correctly, whether through credentialing, Medicare’s Q6 rule, or incident-to billing, ensures compliance, steady cash flow, and uninterrupted patient care.

Ready to Simplify Billing for Locum Tenens or Temporary Providers?

Schedule A Complimentary Consultation with TriumpHealth’s expert billing and coding audit team to learn how we can help you maximize revenue while staying compliant. For more details contact us at 888-747-3836 X0 or email us at [email protected]