Medicare Locum Tenens Rules [2025]

When a physician takes leave—whether for vacation, illness, continuing education, or military service—patient care shouldn’t suffer. That’s where locum tenens (or Fee-for-Time Compensation Arrangements) come in. Medicare allows physicians to bring in temporary substitutes while continuing to bill under their own credentials—but only if strict rules are followed.

From the 60-day coverage limit to proper use of the Q6 modifier, compliance is critical. Billing errors can lead to claim denials, audits, or even fraud penalties. This guide breaks down Medicare’s locum tenens policies, helping physicians and healthcare organizations understand restrictions and navigate exceptions. 

Whether you’re a solo practitioner, a medical group, or a healthcare facility, knowing these rules ensures seamless coverage without risking compliance. And if you need expert support, Era Locums specializes in hassle-free, Medicare-compliant locum tenens staffing.

Medicare Locum Tenens Rules

• What Is Locum Tenens According to Medicare (aka “Fee-for-Time-Compensation Arrangements”)?
• Key Features of Medicare’s Locum Tenens Rule
• The 60 Day Rule for Locum Tenens
• What is the Q6 Modifier for Locum Tenens?
• Concierge Locums Support for Physicians and Healthcare Organizations

What Is Locum Tenens According to Medicare (aka “Fee-for-Time-Compensation Arrangements”)?

Under Medicare, locum tenens (Latin for "to hold the place of") refers to a temporary arrangement where a substitute physician steps in to provide care when the regular physician is unavailable due to reasons such as illness, vacation, continuing medical education, or other absences. Medicare formally recognizes this practice as a Fee-for-Time Compensation Arrangement, allowing the regular physician to bill and receive payment for the substitute’s services as if they had performed them themselves.

Medicare’s Fee-for-Time Compensation policy ensures continuity of care for patients when their usual physician is unavailable. It simplifies billing by allowing the regular physician (rather than the temporary provider) to handle claims, reducing administrative burdens while maintaining compliance.

Key Features of Medicare’s Locum Tenens Rule

1. Independent Contractor Status – The substitute physician is typically paid on a per-diem or fee-for-time basis and functions as an independent contractor rather than an employee of the regular physician.
2. Temporary Coverage Only – The arrangement is intended for short-term coverage, generally not exceeding 60 continuous days (with some exceptions, such as military service).
3. Physician-Only Provision – Only physicians (MDs or DOs) can be billed under this rule. Non-physician practitioners (NPs, PAs, CRNAs, etc.) are excluded, except for physical therapists in certain underserved areas.
4. Billing Under the Regular Physician’s NPI – The regular physician submits claims using their own National Provider Identifier (NPI) while appending modifier Q6 to indicate locum tenens services.

The 60 Day Rule for Locum Tenens

Medicare’s 60-day rule is a key limitation in locum tenens arrangements. Under this rule, a regular physician may bill for services provided by a substitute physician only if the substitution lasts no longer than 60 continuous days per absence. If the substitute physician covers beyond this period, the regular physician can no longer bill under their own NPI—instead, the substitute must enroll in Medicare and bill under their own name starting on the 61st day.

There are two important exceptions to this rule:

• Military Service Exception: If a physician is called to active duty in the Armed Forces, Medicare allows extended billing under the locum tenens arrangement beyond the standard 60-day limit (as outlined in Section 116 of the Medicare, Medicaid, and SCHIP Extension Act).
• New Coverage Period After Return: Once the regular physician resumes practice, a new 60-day period begins if another substitute is needed later.

Additionally, if postoperative care is provided by the substitute, the regular physician cannot bill these services under the Q6 modifier.

What is the Q6 Modifier for Locum Tenens?

The Q6 modifier is a critical component of Medicare billing for locum tenens (Fee-for-Time Compensation) arrangements. When a regular physician submits a claim for services performed by a substitute, they must append modifier Q6 to the procedure code to indicate that the services were furnished under this temporary arrangement.

Key requirements for using the Q6 modifier include:

• The regular physician must pay the substitute on a per-diem or fee-for-time basis (not as an employee).
• The substitute’s services must be properly documented, including their NPI, and records must be retained for Medicare review upon request.
• The regular physician cannot use the Q6 modifier if the substitute exceeds the 60-day limit—after that, the substitute must bill independently.

If you have more questions, we created a complete guide to the Q6 modifier. 

Concierge Locums Support for Physicians and Healthcare Organizations

Navigating Medicare’s locum tenens rules (from the 60-day limit to proper Q6 modifier billing) can be complex. That’s where Era Locums comes in. We specialize in seamless, compliant locum tenens staffing, ensuring your practice or healthcare organization stays covered without administrative headaches.

Why Choose Era Locums?

• Expert Guidance: Our team understands locum tenens inside and out, helping you avoid billing errors or compliance risks.
• Vetted, High-Quality Providers: We connect you with skilled physicians ready to step in, so patient care never skips a beat.
• End-to-End Support: From credentialing to scheduling and billing compliance, we handle the details so you can focus on what matters most.

Whether you’re a physician needing short-term coverage or a healthcare facility managing staffing gaps, Era Locums provides tailored solutions. Let us simplify locum tenens for you so your practice stays running smoothly, no matter what.

Get started online to learn how we can support your locum tenens needs.