TL:DR - The complete locum tenens credentialing process - temporary privileges, PSV, agency coordination, regulatory compliance, and ongoing monitoring.

Healthcare organizations increasingly rely on locum tenens providers to maintain specialty coverage, address physician shortages, reduce burnout, and prevent disruptions in patient care. But while locum staffing solves operational gaps, it also creates one of the most difficult credentialing challenges in healthcare.

Unlike permanent providers who may go through a 90-to-120-day onboarding cycle, locum tenens physicians often need temporary privileges within 24 to 72 hours. The timeline is compressed - but the compliance requirements are not.

Every locum provider must still undergo primary source verification (PSV), exclusion screening, privileging, competency review, peer reference validation, and ongoing monitoring under Joint Commission, CMS, and NCQA standards. Missing even one requirement can expose hospitals and healthcare organizations to accreditation findings, billing violations, patient safety risks, denied claims, and liability exposure.

At the same time, medical staff offices and credentialing teams are expected to move quickly enough to prevent staffing gaps that could affect patient access and revenue continuity.

This guide explains the complete locum tenens credentialing process, including temporary privileges, staffing agency coordination, Medicare billing rules, ongoing monitoring obligations, and operational best practices healthcare organizations use to accelerate credentialing without compromising compliance.

KEY TAKEAWAYS

• The facility bears final responsibility for credentialing locum tenens providers - regardless of what the staffing agency represents.

• State medical license, board certification, and NPDB query must always be independently verified by the facility - these three elements cannot be accepted from an agency file alone.

• OIG exclusion screening must be completed before the provider’s first patient encounter and monthly throughout the engagement.

• Temporary privileges must be granted in writing, with a defined expiration date, specifying exact clinical privileges authorized.

• The Medicare locum tenens billing rule (42 CFR 415.72) allows billing under the absent physician’s NPI for up to 60 consecutive days - but only under specific qualifying conditions.

• Temporary privilege expiration without renewal is the most common locum credentialing compliance violation - set automated 60-day and 30-day alerts.

• Encourage locum providers to maintain a current CAQH ProView profile and participate in the IMLC - both accelerate credentialing at each new facility.

What Is Locum Tenens Credentialing?

Locum tenens credentialing is the process of verifying the qualifications, licensure, and clinical competence of a temporary or substitute provider - and granting them the authority to render patient care at a specific facility - in a compressed timeframe that standard credentialing cycles are not designed to accommodate.

How locum tenens credentialing differs from standard credentialing

Standard medical staff credentialing for locums follows a 60-to-120-day process. Locum tenens credentialing must achieve the same outcome in 24 to 72 hours for temporary privileges - while still meeting all regulatory and accreditation requirements.

This compressed timeline is possible because most locum providers maintain a portable credentialing file through their staffing agency. However, the receiving facility cannot simply rely on this file. Every facility bears independent responsibility for verifying credentials and granting privileges before a locum provider renders care.

Staffing Agency vs. Facility Responsibility: Who Does What?

The most common source of locum tenens credentialing errors is ambiguity about who is responsible for which parts of the process. The Joint Commission and CMS are clear: the facility bears final responsibility for credentialing any provider who renders care within its walls. 

Critical Compliance Point

Under TJC standard MS.13.01.01 and CMS Conditions of Participation, a facility that allows a locum tenens provider to render care without independently verifying credentials and granting formal privileges bears full liability for any adverse patient outcomes - regardless of what the staffing agency represents.

Required Documents for Locum Tenens Credentialing

The following documents are required for locum credentials verification at any Joint Commission-, NCQA-, or CMS-compliant facility.

Required Documents 

• Current state medical license(s) - all states

• DEA registration certificate (with expiry)

• Board certification certificate

• Malpractice insurance face sheet

• Medical school diploma and transcript

• Residency and fellowship certificates

• 10-year work history (no unexplained gaps)

• Current CAQH ProView profile (attested)

Required Verifications

• NPDB query (facility must obtain independently)

• OIG exclusion list check

• SAM.gov federal exclusion check

• State Medicaid exclusion list check(s)

• Minimum 2 peer references (clinical supervisors)

• Malpractice claims history (past 5–10 years)

• NPI (individual) verification

• Signed attestation form

How to Credential Locum Tenens Providers: Step-by-Step Process

The following eight-step process applies to credentialing a locum tenens provider at a hospital or health system. Timeline targets reflect best practice for a well-organized process with a complete agency file.

Step 1:  Request and review the staffing agency's credentialing file [Day 1]

As soon as a locum placement is confirmed, request the provider’s complete credentialing file from the staffing agency. A reputable NALTO-compliant agency should transmit a complete file within 24 to 48 hours.

• Confirm the agency is an NCQA-certified CVO - this determines whether their PSV can be accepted for NCQA or TJC compliance

• Review every document for completeness and currency - expired licenses, outdated malpractice face sheets, and unattested CAQH profiles are the most common deficiencies

• Flag any gaps immediately and request resolution before proceeding

• Document receipt with a date-stamped intake log

Step 2:  Conduct independent primary source verification (PSV) [Days 1–3]

The facility must independently perform PSV for the three elements that cannot be accepted from an agency file alone: state medical license, board certification, and NPDB query.

• State medical license: Verify in real time via the state licensing board’s online verification tool. Confirm active, unrestricted, valid for all states of practice.

• Board certification: Verify via ABMS.org (MD/DO) or the applicable specialty board.

• NPDB query: Submit the facility’s own NPDB query at npdb.hrsa.gov. This is a facility obligation under federal law - you cannot rely on the agency’s NPDB result.

Step 3:  Screen against OIG exclusion and sanctions databases [Day 1 - before care]

No locum tenens provider may render services billed to Medicare or Medicaid unless an OIG exclusion check has been completed and returned clean. The facility must conduct this independently.

• Check the OIG LEIE at oig.hhs.gov - searchable by name and NPI

• Check SAM.gov for federal debarment

• Check applicable state Medicaid exclusion list(s) for every state where the provider will practice

• Document the search date, search terms, and result for each database - required for CMS audit compliance

Step 4: Grant formal temporary or provisional privileges [Before first patient]

Before the locum provider sees their first patient, the facility must issue formal written temporary or provisional privileges. A verbal authorization or email confirmation does not constitute formal privileging under TJC or CMS standards.

• Temporary privileges must be granted by the CEO or designee under TJC standard MS.13.01.01, based on a recommendation from the chief of the applicable clinical department

• The privilege grant must specify the exact clinical privileges authorized - not a blanket authorization to practice medicine

• Set a defined expiration date: typically 30, 60, or 120 days per your facility’s medical staff bylaws

• Assign a proctoring or sponsoring physician from your medical staff for the engagement

Step 5:  Collect and verify peer references [Days 1–10]

At least two peer references from physicians who have directly observed the locum provider’s clinical performance are required - attest to current clinical competence in the specific privileges being requested.

• References must be from practitioners in the same or related specialty with direct knowledge of clinical work - not character references

• Many agencies include peer reference forms in their file - review these but confirm they are current (ideally within 2–3 years) and specific to clinical competence

• Contact references directly if agency-provided forms are outdated or insufficient

• Document the reference verification process: who was contacted, when, and what was confirmed

Step 6:  Complete medical staff committee review and privilege approval [Days 14–45]

While the locum provider renders care under temporary privileges, the full medical staff credentialing process proceeds in parallel. The complete file must be presented to the credentials committee and approved within the temporary privilege period.

• Follow the same medical staff credentials review process used for permanent providers

• If the engagement is short (<30 days), some facilities process a streamlined review under their expedited credentials procedure - verify this is permitted by your bylaws and accreditation requirements

• If the engagement extends beyond the initial privilege period, begin the renewal process at least 30 days before expiration

Step 7:  Establish ongoing monitoring for the duration of the engagement [Continuous]

For the duration of the engagement, the facility must maintain continuous monitoring of the provider’s license status, OIG exclusion status, and any adverse actions or sanctions.

• OIG exclusion screening should be performed monthly throughout any engagement - CMS-recommended standard

• Set up state licensing board alerts or use your credentialing software’s monitoring module

• If the locum provider receives a malpractice claim, license sanction, or adverse action during the engagement, conduct an immediate review

• Require the staffing agency to notify you immediately of any adverse events - document this requirement in your staffing agreement

Step 8:  Manage re-credentialing and engagement renewals [Before expiration]

If a locum engagement extends beyond the initial temporary privilege period, the facility must complete a formal renewal or re-credentialing process before privileges expire. Allowing a locum provider to continue on expired privileges is a TJC and CMS compliance violation.

• Set calendar alerts 60 and 30 days before privilege expiration - do not rely on a manual check

• For recurring locum providers who return regularly, maintain an active credentialing file that is updated at each return rather than starting from scratch

• If the locum arrangement is converting to a permanent position, transition to the standard medical staff credentialing process with continuity of privileges during the handoff

Portable credentialing tip: Encourage locum providers to maintain a current CAQH ProView profile. A complete, attested CAQH profile dramatically accelerates re-credentialing at each new facility.

Temporary and Provisional Privileges: What Facilities Need to Know

Temporary privileges are the mechanism that allows locum tenens providers to render patient care while the full credentialing process is completed. Understanding the regulatory framework is essential for both patient protection and compliance.

KEY REGULATORY STANDARDS GOVERNING TEMPORARY PRIVILEGES

TJC MS.13.01.01

The Joint Commission standard governing temporary privileges for licensed independent practitioners. Permits temporary privileges when there is a verified need to fulfill an important patient care need and initial screening is satisfactory. Grants authority to the CEO or designee.

CMS CONDITIONS OF PARTICIPATION

CMS requires that medical staff bylaws define circumstances under which temporary privileges may be granted and set a maximum duration. The facility’s governing body retains responsibility for ensuring all privileged practitioners meet applicable standards.

NCQA CREDENTIALING STANDARDS

NCQA-accredited facilities must complete primary source verification of at least the medical license before granting temporary privileges. NPDB query must be completed within 45 days of the privilege grant date.

45 CFR PART 60 (NPDB)

Federal regulation requiring healthcare entities to query the NPDB when granting temporary privileges to practitioners not on the medical staff. The facility must query the NPDB - it cannot rely on a query submitted by the staffing agency.

Typical temporary privilege duration policies

Regulatory and Billing Considerations for Locum Tenens

Beyond credentialing, locum tenens arrangements involve specific regulatory and billing rules that directly affect revenue. Understanding these rules prevents claim denials, billing errors, and compliance violations.

The Medicare locum tenens billing rule (42 CFR 415.72)

Under the Medicare fee-for-service locum tenens rule, a substitute physician may bill under the absent physician’s NPI for up to 60 consecutive days - provided the arrangement meets all of the following conditions:

• The regular physician is absent due to illness, vacation, or CME - not simply due to staffing shortages

• The locum physician is not a business partner or employee of the regular physician’s practice

• The substitute renders services on an irregular or occasional basis - not as a permanent replacement

• The regular physician pays the locum on a per-diem or similar basis - not a share-of-revenue arrangement

• The regular physician retains complete responsibility for the services billed under their NPI 

State-specific licensing requirements for locum providers

Locum tenens providers must hold an active medical license in every state where they render care. The Interstate Medical Licensure Compact (IMLC), now active in 40+ states, significantly simplifies multi-state licensing through an expedited pathway to additional state licenses.

Ongoing Monitoring Requirements During a Locum Tenens Engagement

Initial credentialing is the beginning of your compliance obligation - not the end. The facility must maintain active monitoring of the provider’s credentials status for the entire engagement.

Common Locum Tenens Credentialing Mistakes - and How to Avoid Them

Most locum tenens credentialing compliance failures are predictable and preventable. Here are the mistakes that appear most frequently in Joint Commission surveys and CMS compliance audits.

Mistake 1: Relying entirely on the staffing agency’s credentialing file

Agency files are a starting point - not a substitute for independent facility verification. The three elements that must always be independently verified are the state medical license, board certification, and NPDB query. Facilities that accept agency documentation as sufficient often discover this gap during a Joint Commission survey.

Mistake 2: Granting privileges verbally or informally

A department chair saying “she’s good to go” over the phone, or an email from the CMO saying “start Monday,” does not constitute formal temporary privilege granting under TJC, CMS, or NCQA standards. Every privilege grant must be documented in writing, signed by the authorized designee, and filed in the provider’s credentialing record.

Mistake 3: Allowing temporary privileges to expire without renewal

This is the most common locum tenens credentialing compliance violation found in Joint Commission surveys. The engagement continues, but no one noticed that the temporary privilege period ended. The solution is a calendar-triggered alert system - not a manual check - that notifies the credentialing team 60 and 30 days before any temporary privilege expiration.

Mistake 4: Skipping OIG screening because “the agency checked them”

The agency’s OIG check protects the agency. Your facility’s OIG check protects your facility. CMS expects every healthcare organization that bills federal programs to maintain its own exclusion screening records. An agency’s screening result is not acceptable documentation for your CMS audit.

Mistake 5: Not addressing the portable credentialing file at contract time

Your staffing agreement should specify exactly what documents the agency must provide, when, in what format, and what notification requirements apply if the provider receives an adverse action during the engagement. Define everything in writing before placement begins.

Go deeper → How to speed up the healthcare credentialing process

Conclusion

Locum tenens providers play a critical role in helping healthcare organizations maintain continuity of care during staffing shortages, physician leave, specialty coverage gaps, and periods of increased patient demand. But the speed required for locum onboarding also creates significant credentialing and compliance pressure.

Healthcare organizations must balance rapid privileging with strict adherence to Joint Commission, CMS, NCQA, and federal screening requirements. That means independently verifying credentials, conducting exclusion screening before care begins, granting formal temporary privileges, and maintaining continuous monitoring throughout the engagement.

The most effective organizations standardize credentialing workflows, automate monitoring processes, establish clear staffing agency requirements, and build systems designed to support both speed and compliance.

As locum utilization continues to grow across the healthcare industry, efficient credentialing is no longer just an administrative task - it is a critical operational, financial, compliance, and patient safety priority.

Frequently Asked Questions

How long does locum tenens credentialing take?

Full locum credentialing typically takes 30–60 days, while temporary privileges may be granted within 24–72 hours if required documentation and screenings are complete.

Can hospitals rely entirely on staffing agency credentialing files?

No. Facilities must independently verify key elements, including medical licenses, board certification, and NPDB queries.

Is an NPDB query required for temporary privileges?

Yes. Healthcare organizations must independently query the NPDB when granting privileges to practitioners.

How often should OIG checks be performed for locum providers?

Best practice and CMS guidance support monthly exclusion screening throughout the engagement.

What happens if temporary privileges expire?

Allowing providers to continue practicing after privileges expire creates Joint Commission and CMS compliance violations and may expose the facility to liability risk.

Do locum providers need credentialing at every facility?

Yes. Each healthcare organization must independently credential and privilege locum providers before patient care begins.

Can locum providers bill under another physician’s NPI?

Under Medicare fee-for-service rules, substitute physicians may bill under the absent physician’s NPI for up to 60 consecutive days if all CMS conditions are met.

Streamline Locum Tenens Credentialing With Tollanis Solutions

Tollanis Solutions helps healthcare organizations simplify locum provider credentialing workflows, improve compliance visibility, reduce onboarding delays, and support efficient locum tenens management.

From credential tracking and verification coordination to ongoing monitoring support, our healthcare credentialing solutions help organizations reduce administrative burden while maintaining audit readiness and operational continuity.