If you die, can your estate hire a locum tenens to see patients?

Here's an interesting question: May a locum tenens doctor fill in for a deceased doctor? Answer per Part B News (https://pbn.decisionhealth.com/): No. You may not report services with a deceased provider’s name and billing identification information, therefore you may not use a locum tenens provider to stand in for that doctor.

According to Medicare administrative contractor Palmetto GBA notes: “Since contractors are required to terminate a deceased provider’s enrollment, you cannot submit a locum tenens service under the deceased provider’s National Provider Identifier (NPI). The performing physician must submit the services under their own NPI.” Palmetto cites the Program Integrity Manual – CMS 100-08, chapter 15, §15.28 – as the source for its answer.

In a FAQ on the same topic, Noridian states “services rendered after a physician deceases may not be billed under the locum tenens or reciprocal billing reassignment exceptions. The physician's Provider Transaction Access Number (PTAN) and National Provider Identifier (NPI) must be termed if they are deceased.”

• CMS 100-08, chapter 15, §15.28: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/pim83c15.pdf
• Noridian – Locum tenens arrangements: https://med.noridianmedicare.com/web/jea/provider-types/locum-tenens-and-reciprocal-billing
• Palmetto GBA – Frequently asked questions-locum tenens: https://www.palmettogba.com/Palmetto/Providers.nsf/docsCat/Providers~JM%20Part%20B~Browse%20by%20Topic~Frequently%20Asked%20Questions?open&Cat=Locum%20Tenens