Your Doctor Is Out. Can an NP or PA Take Over? The Medicare “Locum Tenens” Trap

By Tatyana Kantor, CFPC, CPB, Billing Department, WCH  

The Scenario Every Practice Thinks Is Routine

Dr. Smith is going on a two-week vacation. Jane, the practice’s NP, will see his patients while he’s gone. The front desk doesn’t think twice about it — it’s just coverage, the same thing practices have done for decades. The billing team appends modifier Q6 to the claims and submits them under Dr. Smith’s NPI, because that’s how the practice has always billed for “temporary coverage.”

Medicare disagrees. Not with the coverage — with the bill.

That single mismatch — between how a practice experiences temporary coverage and how Medicare classifies it for payment — is where a routine staffing decision quietly turns into a billing violation. The error may remain invisible until a payer review, internal audit, or retrospective claims analysis identifies a pattern across multiple claims.

The underlying issue is broader than one modifier. Medicare does not treat every form of temporary clinical coverage as the same billing arrangement — and NP/PA substitution is simply the clearest example of what happens when a practice assumes it does.


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