HCPCS Modifier Q6

Description
Service furnished under a Fee-For-Service Time Compensation (Previously known as Locum Tenens) arrangement by a substitute physician or by a substitute physical therapist furnishing outpatient physical therapy services in a health professional shortage area, a medically underserved area, or a rural area.

Guidelines and Instructions
Submit HCPCS modifier Q6 to indicate that services were provided under a Fee-For-Service Time Compensation arrangement.

Fee-For-Service Time Compensation Background

• Physicians may retain substitute physicians to take over their professional practices when they are absent for reasons such as illness, pregnancy, vacation or continuing medical education
• These substitute physicians, known as Fee-For-Service Time Compensation physicians, generally have no practice of their own and move from area to area as needed
• The regular physician generally pays the substitute physician a fixed per diem amount. The substitute physician's status is that of independent contractor, rather than employee, and his/her services are not restricted just to the physician's office.
• Services of non-physician practitioners (e.g., CRNAs, NPs and PAs) may not be billed under the Fee-For-Service Time Compensation or reciprocal billing reassignment exceptions. These provisions apply only to physicians.

The regular physician may submit a claim under the Fee-For-Service Time Compensation arrangement using his or her own National Provider Identifier (NPI) and, if assignment is taken, receive payment for covered visit services if the following conditions are met:

• The regular physician is unavailable to provide the visit/services
• The Medicare patient has arranged or seeks to receive the visit/services from the regular physician
• The regular physician pays the Fee-For-Service Time Compensation physician for his or her services on a per diem or similar fee-for-time basis
• The substitute physician does not provide the visit/services to Medicare patients over a continuous period of longer than 60 days
• The regular physician identifies the services as substitute physician services with HCPCS modifier Q6 (services furnished by a Fee-For-Service Time Compensation physician). Until further notice, the regular physician must keep on file a record of each service along with the substitute physician's NPI.
• If postoperative services are furnished by the substitute physician, the services cannot be submitted with HCPCS modifier Q6 since the regular physician is paid a global fee
• If services are provided by a substitute physician over a continuous period of longer than 60 days, the regular physician must submit the first 60 days with HCPCS modifier Q6
• The substitute physician must submit for the remainder of the services in his/her own name
• The regular physician may not submit and receive direct payment for services over the 60-day period
• A new period of covered visits can begin after the regular physician has returned to work

For a medical group billing under the Fee-For-Service Time Compensation arrangement, it is assumed that the Fee-For-Service Time Compensation physician is paid by the regular physician.

• The term regular physician includes a physician who has left the group and for whom the group has hired the Fee-For-Service Time Compensation physician as a replacement
• A physician who has left a group, and for whom the group has engaged a Fee-For-Service Time Compensation physician as a temporary replacement, may still be considered a member of the group until a permanent replacement is obtained

Exception to the 60-Day Limitation for Fee-For-Service Time Compensation

• Section 116 of the Medicare, Medicaid and SCHIP Extension Act of 2007 extended the exception to the 60-day limit on substitute physician billing for physicians being called to active duty in the Armed Forces for services furnished from January 1, 2008, through June 30, 2008. Section 116 of Public Law 110-173 extended the accommodation of physicians ordered to active duty in the Armed Forces, enacted by Public Law 110-54, by striking January 1, 2008, and inserting July 1, 2008.
• Essentially, both legislative acts allow a physician being called to active duty to bill for the services furnished by a substitute physician for longer than the 60-day limitation

References

• CMS Pub. 100-04, chapter 1, section 30.2.1.H, 30.2.11, and 30.11.B (PDF, 1.63 MB)