Fee-For-Time Compensation Arrangement and Reciprocal Billing Job Aid

Fee-For-Time Compensation Arrangement and Reciprocal Billing Job Aid
Fee-For-Time Compensation Arrangements
Reciprocal Billing Arrangements
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Fee-For-Time Compensation Arrangement and Reciprocal Billing Job Aid

The Social Security Amendments Act of 1994 allowed, on a permanent basis, for payment to be made to a patient’s regular physician and not a substitute physician, in the event that a fee-for-time compensation arrangement or reciprocal billing arrangement existed. The regular physician must submit the services using his/her own NPI.

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Fee-For-Time Compensation Arrangements

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-time compensation arrangement 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 nonphysician practitioners (e.g., CRNAs, NPs and PAs) may not be billed under the fee-for-time compensation arrangement or reciprocal billing reassignment exceptions. These provisions apply only to physicians.

The regular physician may submit a claim under the fee-for-time compensation arrangement using his/her own 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-time compensation arrangement physician for his/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-time compensation arrangement physician). Until further notice, the regular physician must keep on file a record of each service along with the substitute physician’s NPI.

Exception to the 60-day limitation for fee-for-time compensation arrangement billing:

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 1/1/2008, through 6/30/2008. 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.

If postoperative services are furnished by the substitute physician, the services cannot be billed 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 bill the first 60 days with HCPCS modifier Q6.
The substitute physician must bill for the remainder of the services in his/her own name.
The regular physician may not bill 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-time compensation arrangement, it is assumed that the fee-for-time compensation arrangement 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-time compensation arrangement physician as a replacement.
A physician who has left a group, and for whom the group has engaged a fee-for-time compensation arrangement physician as a temporary replacement, may still be considered a member of the group until a permanent replacement is obtained.

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Reciprocal Billing Arrangements

On an occasional reciprocal basis, a patient’s regular physician will arrange for a substitute physician to provide visit/services, including emergency visits or related services. Under a reciprocal billing arrangement, the patient’s regular physician may submit a claim to Medicare Part B using his/her own NPI and, if assignment is accepted, receive payment 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 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 by using HCPCS modifier Q5. (services furnished by a substitute physician under a reciprocal billing arrangement)
Until further notice, the regular physician must keep on file a record of each service provided by the substitute physician along with the substitute physician’s NPI.

If postoperative services are furnished by the substitute physician, the services cannot be billed with HCPCS modifier Q5 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 bill the first 60 days with HCPCS modifier Q5. (services furnished by a substitute physician under a reciprocal billing arrangement)
The substitute physician must bill the remainder of the services in his/her own name.
The regular physician may not bill and receive payment for services over the 60-day period.
A new period of covered visit/services can begin after the regular physician has returned to work.

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Fee-For-Time Compensation Arrangement and Reciprocal Billing Job Aid

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