CMS Modifies the 60-Day Limit for Locum Tenens During the COVID-19 Public Health Emergency

March 2, 2022

The Centers for Medicare and Medicaid Services (CMS) has modified the 60-day limit for the use of a substitute physician during the Public Health Emergency (PHE).  CMS will allow the use of the same substitute physician during the entire public health emergency, and for an additional 60 days after the PHE ends.  

On or before the 61st day after the end of the PHE, the regular physician must report back for at least one day to reset the 60-day clock, or a different substitute physician must be used if one is still needed, both essentially restart the 60-day clock.  This temporary flexibility in the Locum Tenens requirements allows for a substitute physician to work beyond the standard 60-day limitation for a provider.  

Those providers who choose to use a locum for longer than 60 days during the Public Health Emergency will need to append a CR modifier on day 61 to alert CMS that the provider is utilizing this flexibility during the PHE.

As a reminder, any physician who has been called for active duty in the armed forces may utilize the same substitute for an unlimited time even after the emergency ends. 

For additional information regarding this temporary update on Locum Tenens billing, please click here and see page 35 and/or here, page 4.  All other standard Locum Tenens rules still apply.  Please click here and see page 70 for more information on these requirements.     

APS looks to provide ongoing support and information to our clients.  As always, APS will continue to monitor and provide updates as they become available.