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Billing as Locum when your Not Locum ??


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I recently left a job as it was a sketchy situation.

 

I am concerned as I heard yesterday that you can not be billed as a locum when you are not working for a locum company. This place hired me and had me start one week later. I didn't know the rules I had never been a locum before. I was billed under the MD# for everything. I don't know if I was seeing patients legally ? all the other places it took like a month or 2 !

 

Its the weekend and no one to call and ask, hope someone out there.... might know?

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oh no

• A practice may bill for a locum tenens physician using the provider number of the absent physician (vacation, medical leave, etc.) for up to 60 continuous days. The presumption is that the absent physician will return. A locum tenens physician must be a credentialed Medicare provider (other than for your practice), and a record of that physician's National Provider Identifier should be on file with the carrier. Locum physicians should not have a practice of their own. The services must be billed using the modifier –Q6 to show that it is a locum tenens physician, and a record of the services provided to your patients by the locum tenens physician must be kept. The locum tenens physician is considered an independent contractor, and compensation must be based on a fixed amount (such as a per diem). After 60 continuous days, locum tenens physicians may no longer see patients or bill for services with anything other than their own NPI specifically attached to your practice and Tax ID number.

http://medicaleconomics.modernmedicine.com/medical-economics/news/modernmedicine/modern-medicine-now/qa-how-bill-locum-tenens-during-transition?page=full

 

 For practices that have contracted with a locum tenens physician to provide services for the patients of a physician who was terminated or voluntarily left the practice: The same rules apply as for a physician who is on sabbatical or vacation. Services should be reported with modifier –Q6, and the period of time cannot exceed 60 days. If you are recruiting physicians, you cannot bill the services of those physicians before they are credentialed as locum tenens, because they do not meet the requirement that the provider be credentialed with Medicare. Another caveat to this scenario is that if the departing physician notifies the carrier of his departure and removes your practice affiliation (tax ID, location, etc.) from his profile, you will not be able to bill for any locum tenens physician using the provider numbers of the departed physician.

 

So am I totally screwed ?

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Wouldn't you be an independent contractor? You'd still have to be assigned, legally,a new sp, even if temporary

 

Sorry, just read that whole text you copied... You're not a doc, so the whole thing is different. You should just need a change in your SP, working under your npi with his supervision as a contractor I guess

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Well the biggest thing is YOU ARE NOT A PHYSICIAN

 

They allow this type of billing for doc's

 

I am no attorney, but if they are billing at doc rate, for a PA, that is an employee, well that seems scetchy

 

 

 

 

******************After 11 years, and about 6 jobs as a PA I opened my own practice, and was shocked to find out I was not credentialed, and NEVER had been, with medicare.  I had EVERY SINGLE visit billed under ALL my SP's.  It is sort of an industry norm I guess.........

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Oh. My. God. You are very likely screwed.

Kids, KNOW YOUR STATE PRACTICE LAWS INSIDE AND OUT! Your employer will not know them and can't be relied on to uphold them. They will likely break them whenever they think they can get away with it. It's fine to trust...after you verify.

My heart breaks a little if your program didn't teach you the legalities of PA practice in your state. If you trained elsewhere, ok, but the onus is on the PA to do your own research and learn the laws of your state.

This is bad. I hope someone at the BME takes pity on you and goes light on your ignorance of whether you were appropriately licensed before beginning work at that site.

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Guest Paula

Do you have a copy of your PA license or a temporary PA license?  Most practices don't allow you to start working until they SEE the license. 

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Some states put you in a catch-22 of requiring you have a supervisory agreement BEFORE you can get a license. 

This brings up additional issues that if your SP dies, quits, moves, or fires you, you immediately lose your license in those states (unless you have multiple supervisory physicians).

Rookie - can you give us further info on exactly HOW you were practicing without a license??  How in the world did that happen??

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Guest Paula

Some states put you in a catch-22 of requiring you have a supervisory agreement BEFORE you can get a license. 

 

This brings up additional issues that if your SP dies, quits, moves, or fires you, you immediately lose your license in those states (unless you have multiple supervisory physicians).

 

Rookie - can you give us further info on exactly HOW you were practicing without a license??  How in the world did that happen??

 

What states have that rule of LOSING your license if the SP dies, quits, etc.?  In my 2 practice states I would immediately be out of a job or unable to practice but I would not lose my PA license.  This situation is one of the primary reasons I believe PAs should have independent licenses that are not tied to another profession. I see it now as a restraint of trade and the BOMs need to change their rules....or rather PAs need to legislate for free and independent licenses and go to battle with the BOMs.  

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Happened to me in SC in 2011. Didn't lose my license but it was immediately inactive and took almost 6 mos to reinstate with a new SP. I was in med school in PA but still royally pissed off.

SCAPA apparently finally fixed this last year. If I had not been in med school living on loans I would have been financially incapacitated.

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Guest Paula

Happened to me in SC in 2011. Didn't lose my license but it was immediately inactive and took almost 6 mos to reinstate with a new SP. I was in med school in PA but still royally pissed off.

SCAPA apparently finally fixed this last year. If I had not been in med school living on loans I would have been financially incapacitated.

 

My greatest concern is just that.  I would lose my income and I am the major breadwinner so it would decimate us if I couldn't find a job within a couple of weeks.  And at my age I have already experienced age discrimination so I don't think it would be easy to find another job quickly. 

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What states have that rule of LOSING your license if the SP dies, quits, etc.?  In my 2 practice states I would immediately be out of a job or unable to practice but I would not lose my PA license.  This situation is one of the primary reasons I believe PAs should have independent licenses that are not tied to another profession. I see it now as a restraint of trade and the BOMs need to change their rules....or rather PAs need to legislate for free and independent licenses and go to battle with the BOMs.  

I shouldn't have said "lose", but rather "go inactive". 

 

That's one reason why I have multiple supervising physicians.

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I shouldn't have said "lose", but rather "go inactive".

 

That's one reason why I have multiple supervising physicians.

Definitely the fix for that problem! Only time in nearly a decade that I had been down to one SP. It was a foolish oversight not to have alternates designated. Actually, probably a year before, I had printed the alternate signature list, signed it myself, passed it around to a few different docs and the admin never sent it. I was wrapped up in school when this happened and I was blindsided. In other states it wouldn't have been as much of a problem to have one SP up and decide he wasn't going to work at that ER anymore. I blame admin also because they used this guy as locums and needed him elsewhere AND needed him to supervise new PAs there. I'll bet they even drafted the letter and sent it to the BME after he signed it. They just didn't think to tell ME.

That was really good incentive to stay in med school at a time I wanted to quit.

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Guest Paula

I may need to ask to have an alternate physician backup but I know I won't get one.  We are a single physician clinic and one PA.  Dysfunctional administration and they would probably think about not renewing my contract (coming up soon now to start renegotiation in August with finalizing due Nov.) and just hiring a second doctor, no PA or NP, or hiring an NP.  (They falsely think the NP is independent in this state...it's not...needs DEA oversight and they can't write for schedule II).

 

It's dicey having to deal with a new Health Director who thinks completely different than the previous one.   The new one is not as PA friendly and told me if needed they would only hire an NP for a new position...partly because of meaningful use reimbursements and I don't qualify since I don't lead this FQHC. NPs qualify tho. 

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It's dicey having to deal with a new Health Director who thinks completely different than the previous one.   The new one is not as PA friendly and told me if needed they would only hire an NP for a new position...partly because of meaningful use reimbursements and I don't qualify since I don't lead this FQHC. NPs qualify tho. 

 

And THIS is where you and I really disagree on where we as PAs should put our limited political influence.  I would rather spend our time and efforts changing laws such as this than changing our name and oversight. 

 

If you like rural medicine there is a big need in the state right above you (if you are where I think you are).

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Guest Paula

I live in Northern Wisconsin and travel 50 miles north the the Upper Peninsula, Michigan.  No states right above Michigan unless there is a clinic on an island in Lake Superior....now that I think of it actually there is and there used to be an NP there occasionally during the summer.   Or were you thinking Canada? Alaska off to the Northwest??? 

 

In my ideal world PAs have all restrictions removed, collaboration instead of supervision, independent licenses granted by the BOMs or a PA BOM, (collaboration is described as collaborating with a physician(s), group of physicians, or referral physicians as needed) and PAs can practice when a collaborating physician dies because it doesn't matter as long as they collaborate with a group, etc.  For example, I call a particular cardiology group for issues I need answers on immediately and our referrals go largely to that group as they are within a reasonable distance for our patient to travel to, and the group has an excellent reputation, plus they are willing to work with our small clinic.  Same thing for our surgical cases that go to a different group in a different town. 

 

Billing restrictions lifted...yes.  Meaningful use given to PAs...yes.  PAs able to be credentialed as PCP in all insurance plans....yes.  No co-sig by a physician for DME....yes.  They all need to be deleted from laws and CMS.  SO I agree with you on all of that.  For now I am content to call myself a PA.  Not midlevel or anything else.

 

I realize funds are scarce at the AAPA and in state chapters so we do what we can and our political influence pales in comparison to the nursing lobby.  I get it. 

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  • 2 weeks later...

Had the license but not the aproval.

I had been out of America almost 2 years, trusted the Doc and I should not have.

They are illegaly keeing my last check.

The State Board has been very understanding I went to them the moment I realized. They are upset with the MD and will be talking to him. IDK how this will effect my malpractice insurance. LOTS of other issues , never had a blood born path, no incendent forms, no policies , no sop, MD abandonded me,  Co Worker Assulted. Etc etc ext, I left the job, they wont accept that i have quit ! took the lazy CEO 11 days to respond to the fact I had quit only to tell me he was letting me have ' cool down' time, and that he was keeping the 6k he owed me and I owe him 250.01 and he threated to turn me into the state medical board (* not knowing i had spoken to them myself), unless I kept my mouth shut and came back to work for him ( yes the dummy put it in an email even!!!) Sooo kinda like blackmail? threatening me and keeping my money. So I had to report them to L&I (its what you do when someone illegally keeps your last paycheck) so, this is gone from bad to worse.

I dont want to go back and live in Irealnd , I want to bring my husband here. I would have never quit unless it was as bad as it was. This means I wont see him for ANOTHER year... and right now I am not seeing a lot of love in America for immigrents , its only going to make it harder for us to be together again. Thank you all for the support and advice. I will let you know what happens next..

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My guess is she had the license but no supervision agreement on file with this doc.

BINGO

I did have all the training on this in school and all, but i had been gone almost 2 years and old books i gave back to my college before i left America.

 

I was just being stupid, excited about a new job , they said it was SOP, and I bought it.

Its only when i saw them breaking every other law , catching them lying to me on other issues i began to dig, and .... it was terrible i cant think of an area of medicine where they have not wilfully broken law , codes, ethics etc :(

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Some states put you in a catch-22 of requiring you have a supervisory agreement BEFORE you can get a license. 

 

This brings up additional issues that if your SP dies, quits, moves, or fires you, you immediately lose your license in those states (unless you have multiple supervisory physicians).

 

Rookie - can you give us further info on exactly HOW you were practicing without a license??  How in the world did that happen??

Had the license, (the practice plan and all other paperwork was not done for months) , i was told it was 'oked' and that ' this happens all the time

'. My Doc has been in medicine 50 years I thought .....he knows his stuff...... No,  Really he doesnt give 2 shits anymore if they take his license his turning that place into a pill mill ... hes in it for the cash thats all

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  • 2 weeks later...

... and right now I am not seeing a lot of love in America for immigrents , its only going to make it harder for us to be together again. Thank you all for the support and advice. I will let you know what happens next..

 

America loves LEGAL immigrants.

 

It's the ILLEGAL immigrants that half of the country wants to get rid of. 

 

Big difference.

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