Fam Pract Manag. 2017 May-June;24(3):34.

Billing for physicians while credentialing is pending


A new physician in my practice is awaiting credentialing. In the meantime, should he bill as a locum tenens physician?


No. The new physician would have to be working under a contract to provide temporary services in order to bill as a locum tenens physician. A better solution may be to bill incident-to another physician within the group. New physicians may do this while waiting for credentialing as long as all incident-to requirements are met (e.g., they are continuing a treatment plan established at a prior encounter with no changes or new problems addressed and there is direct supervision by the reporting physician). Medicare permits incident-to billing for a physician's services, but private payers may not. You should check with them to be sure.

Defining 24/7 access to care for chronic care management services


Is use of an answering service or patient portal acceptable for providing 24/7 access to care as required for chronic care management services?


Use of an answering service or patient portal must be coordinated to allow for a prompt response to an urgent need. Merely allowing a message to be left for the next business day would not meet the requirement for 24/7 access to care. Medicare and CPT specify that the 24/7 access requirement pertains to care for urgent needs regardless of the time of day or day of week. Medicare's position was described in the final rule for the 2017 Medicare Physician Fee Schedule, which states that care models for providing 24/7 access to care include various contractual relationships between physician practices and other health care providers including telephone triage systems and health information technology such as shared electronic health records and systematic notification procedures. Some or all of these may be used to

About the Author

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Cindy Hughes is an independent consulting editor....

Author disclosure: no relevant financial affiliations disclosed. Reviewed by the FPM Coding & Documentation Review Panel: Kenneth Beckman, MD, MBA, CPE; Robert H. Bösl, MD, FAAFP; Marie Felger, CPC, CCS-P; Thomas A. Felger, MD, DABFP, CMCM; Emily Hill, PA-C; Joy Newby, LPN, CPC; and Susan Welsh, CPC, MHA.


Send questions and comments to, or add your comments below. While this department attempts to provide accurate information, some payers may not accept the advice given. Refer to the current CPT and ICD-10 coding manuals and payer policies.


Copyright © 2017 by the American Academy of Family Physicians.
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