Fee-For-Time Compensation Arrangements

1. Can a physician return to work in his or her practice for a short period of time to reset the 60-day clock requirement for the fee-for-time compensation arrangement provider?
   
   Answer: In order for the clock to reset on the 60 days, the physician on leave would need to return to practice, perform services, file claims and then go back on leave. The only option for the covering physician is to pursue Medicare enrollment, which can be a lengthy process, but would allow that physician to bill under his/her own Medicare number.
    
2. Fee-for-time compensation arrangement guidelines indicate that the arrangement should not last longer than 60 days. Please define 60 days as relative to calendar days, business days or the first 60 days during which the fee-for-time compensation arrangement physician is providing coverage (which wouldn’t necessarily be continuous)?
   
   Answer: NGS interprets the 60 calendar days to be continuous from the date on which the fee-for-time compensation arrangement physician is providing coverage.

Reviewed 10/8/2024