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Physical Therapy Locum Tenens

September 4, 2015 0 Comments

Physical therapy locum tenens is once again on the on the legislative “must do” list in 2015.  iStock_000005244112XSmallFirst, you may be wondering what does physical therapy locum tenens mean?  In short, if you are a physical (or occupational, or speech) therapist in a small private practice and you or one of your staff members takes a vacation, medical leave, or leaves your practice without a replacement, you look to have another therapist fill to treat patients.  Except the “fill in” therapist is likely not credentialed with all your health plans or Medicare.  Even if a potential “fill in” therapist is credentialed with Medicare, it would still take time to update their enrollment in order to reassign benefits (payments) to your private practice.   Unfortunately physical therapists, occupational therapists and speech-language pathologists are not among the list of professionals that quality for locum tenens.

Physical Therapy Locum Tenens  How it Works

In short, locum tenens  is the ability of a private practice to bring in a “temporary” staffer to treat patients and bill the Medicare program.  According to the APTA in rural areas “a locum tenens provider can keep a small practice open to serve patients who would otherwise have to travel large distances to another provider.”  The Prevent Interruptions in Physical Therapy Act (H.R. 556/S. 313), has been introduced by Representatives Gus Bilirakis (R-FL) and Ben Ray Lujan (D-NM) for the House and Senators Chuck Grassley (R-IA) and Bob Casey (D-PA) for the Senate.

Locum tenens arrangements under Medicare must meet regulatory standards, including the identification of these services through a modifyer on the claim form and a 60-day limitation on the use of a temporary provider.  According to the APTA:

For many physical therapists in private practice, this means that they may be unable to take these absences, or they must interrupt patient care. Locum tenens arrangements are benefi cial to both patients and providers as care is continued by another licensed  qualified provider during a temporary absence.

While the legislation that has been introduced, there is not any way for a physical therapists to substitute for a occupational therapist and vice versa.  From a practice act view point this is not allowable and from a Medicare credentialing viewpoint there is no interchangeability.  Most questions arise when hand therapists (where physical and occupational therapists can earn the “certified hand therapists” (CHT) credential, seek to “hand therapy” converge for their patients in their absence. So a physical therapy CHT seeking coverage for  Medicare patient with a occupational therapist CHT should do so knowing that the occupational therapist would have to develop a separate plan of care, creating potential reimbursement challenges, but also extra expense if likely to the Medicare program and the beneficiary.

Of note, therapists in hospitals, skilled nursing facilities, rehab agencies and other institutional providers do no have this concern, as the facility is enrolled in Medicare, not the individual therapist.  So even a small rehab agency, or small hospital therapy department may fill in with a temporary therapist that is not enrolled in Medicare.

Do you have a small practice?  Is patient care compromised when you cannot find a “fill in” therapist.  Have you contracted your senators and representative to request their support of this bill?

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Nancy Beckley

Nancy J. Beckley MS, MBA, CHC: President-Nancy Beckley & Associates LLC. Compliance outsourcing, risk assessment, compliance plans, compliance training, auditing, due diligence, investigation support for therapy providers.

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