Whether you need someone to cover your patient appointments while you’re out of town for the holidays, or you could use an extra pair of hands to help with the seasonal rush, you may be searching for a temp or travel PT. Of course, you’ll want to hire the very best person for the job—but you’ll also want to ensure they’re fully credentialed so you can properly bill and collect payment for their services. With that in mind, here’s everything you need to know about billing for temps and travel PTs:
Some PTs can now take advantage of what was previously known as locum tenens.
Locum tenens, a Latin term that roughly translates to “placeholder,” refers to an arrangement in which eligible healthcare providers can use a modifier to indicate that a replacement practitioner provided services to their patients on a particular day—and can still receive full compensation for those services. This summer, Medicare announced that it was no longer using the term locum tenens in this capacity, but for the sake of clarity and continuity, I’ll continue to do so for the remainder of this article. Unfortunately, this type of arrangement does not yet extend to all rehab therapists—although, a few years ago, it didn’t extend to any, so there has been some progress.
Advocacy in Action
According to this APTA resource, in 2015, Senators Charles Grassley and Bob Casey—as well as Representatives Gus Bilirakis and Ben Ray Lujan—introduced the Prevent Interruptions in Physical Therapy Act. In support of the Act, during a Senate Finance Committee hearing, Grassley said, "physical therapists provide important and much needed services to their patients, and should have the ability to ensure continuous care for their patients when a period of short-term care is needed." While the Act was supposed to extend to all PTs, it was scaled back due to some concern over implementation costs. Thus, as of June 13, 2017, private practice PTs—Provider Specialty 65—who practice in “non-metropolitan statistical areas, medically underserved areas (MUAs), and health professions shortage areas as defined by the US Department of Health and Human Services” can take advantage of locum tenens arrangements.
MUAs, HSPAs, and Rural Areas
To determine whether you practice in a region that is considered a medically underserved area (MUA) or health professions shortage area (HPSA), the APTA recommends visiting the HRSA’s website. To determine whether you practice in a non-metropolitan statistical area (i.e., a rural area), the APTA suggests providers “consult the Crosswalk of Counties to Core-Based Statistical Areas in the most current Inpatient Prospective Payment System (IPPS) final rule.” Apparently, “any area that is not designated as urban in the crosswalk is rural.” For more detailed instructions on accessing the crosswalk, check out the APTA page.
The Fine Print
According to the APTA, eligible physical therapists may use locum tenens—that is, “bill Medicare for services performed by a locum tenens PT under the regular PT’s NPI”—if they are “absent for a limited period of time for vacation, disability, continuing education, etc.” and the following conditions are met:
- The regular PT is not available to provide care.
- The replacement PT is “compensated on a per diem or similar fee-for-time basis.”
- The regular PT doesn’t use locum tenens for more than 60 continuous calendar days. (If the regular PT returns to work and must leave again, he or she may re-hire the same locum tenens PT “and a new 60-day period begins.”)
- The PT “uses a modifier [Q5 or Q6] to indicate that the services were provided by a locum tenens PT.”
Per this CMS document, providers who are “called or ordered to active duty as a
member of a reserve component of the Armed Forces” may use locum tenens for more than 60 continuous days. It also indicates that services in the arrangement can be “informal and reciprocal or involve per-diem or other fee-for-time compensation.”
Everyone else must solve the “bill as” problem.
As WebPT co-founder and president Heidi Jannenga wrote in this post, in order to “bill as” correctly—and thus “receive reimbursement from your insurance companies, the contractor you hire to cover you must be fully credentialed with the same insurance companies whose beneficiaries you treat.” The best way to ensure your temps and travel PTs are fully credentialed is to hire them through a “qualified agency with vetted insurance credentials,” she said. While “this may be a slightly more costly way of doing things compared to simply hiring a friend or associate,” it’s still “your best choice.”
This is especially important for Medicare beneficiaries, because billing Medicare for services provided by a non-credentialed therapist could leave you “vulnerable for fraud charges,” said James Ko, the author of this resource. Ko actually suggests reaching out to him privately if you’ve made this mistake in the past; he’ll help you determine the severity of the situation and recommend an attorney to help remedy it.
With non-Medicare insurance companies, rehab therapists may have some wiggle room—depending on the specifics of their payer contracts. According to Ko, if there is no specific language in your contract that requires your substitute therapists to be fully credentialed, you may be able to get away with “having another therapist (who is credentialed) present during their service” or “at the very least, make sure to co-sign all the notes.” According to Jannenga, though, in order to co-sign a note, the credentialed therapist must provide direct onsite supervision. So, in essence, you would bill for the services provided by a non-credentialed sub the same way you would for a PTA.
No one said billing for healthcare services was going to be easy—or simple. But at least we’re starting to move in the right direction, with the powers that be affording physical therapists—and their patients—some of the same courtesies other providers already enjoy. What has been your experience with billing for temps and travel PTs? Share in the comment section below.