Locum tenens coverage has become increasingly common in telehealth, whether to fill a temporary staffing gap or to provide coverage across time zones. Billing for locum tenens work involves specific conventions, and adding a remote-visit component introduces a few additional considerations worth understanding in general terms.
What locum tenens billing generally involves
Under Medicare's locum tenens framework, a regular physician who is temporarily unavailable can arrange for a substitute physician to see patients, with the regular physician's practice billing for those services under specific modifiers rather than the substitute physician billing independently. This arrangement was designed with reciprocal billing and time-limited coverage in mind, and it typically comes with limits on how long a single locum arrangement can last before different billing rules apply.
How telehealth changes the picture
When locum tenens coverage is delivered by telehealth rather than in person, licensure becomes a separate and important consideration alongside the billing rules. The substitute physician generally needs to hold an active license, or qualify under an applicable exception or compact pathway, in the state where the patient is physically located at the time of the visit — not simply where the regular physician's practice is based. This is true regardless of whether the coverage is billed under locum tenens conventions or independently, and it is a distinct requirement from the Medicare billing rules themselves.
Locum tenens billing rules and state licensure requirements are separate systems, and telehealth coverage means both generally need to be checked before a substitute physician sees a single patient.
Documentation practices worth considering
Practices using telehealth locum tenens coverage commonly keep a record of which physician saw which patient, on what dates, and under what licensure basis, since this documentation can matter both for billing audits and for demonstrating licensure compliance if a question arises later. Confirming DEA registration status for the covering physician is also relevant if any controlled substance prescribing is involved, since DEA registration and state licensure are handled through separate systems with their own requirements.
A general note on payer variation
Commercial payers do not always follow Medicare's locum tenens conventions exactly, and some have their own credentialing or notification requirements for temporary coverage arrangements. Practices relying on locum tenens telehealth coverage across several payers typically find it useful to confirm each payer's specific policy rather than assuming Medicare's rules apply uniformly.
Requirements vary by state and change over time — always confirm current requirements directly with the relevant state board or agency before making a compliance decision.