# Your locum tenens placements each carry a registration question nobody answers before day one.

![An agency compliance lead checking clinician licence and credentialing status against an upcoming placement start date on an office screen, used to show where placements are actually cleared.](https://neurobird.com/locumtenens/locumtenens-hero.webp)
*Registration attaches to a place. Availability attaches to a person. Placements need both.*

> Locum tenens staffing is the practice of placing clinicians temporarily into a facility to cover a vacancy or an absence. It is a staffing business sitting on top of a licensing and registration regime: the clinician needs state licensure, the facility needs them credentialed and privileged, and where controlled substances are involved a registration question arises for each location rather than for the person alone.

- URL: https://neurobird.com/locumtenens/
- Product: Neurobird Locum Tenens Staffing Compliance Platform
- Niche: locum tenens staffing
- Buyer: locum tenens agencies and hospitals
- Status: in development, open for early access
- Updated: 2026-08-26

## What Neurobird Locum Tenens Staffing does

- Check licensure, credentialing and registration against the specific facility before confirming a placement.
- Track expiry dates against assignment dates, since a mid assignment lapse strands both parties.
- Record which registrations cover which locations, because that is how the rules are written.
- Keep the credentialing file with the placement so a facility audit is answered from records.

## How it works

1. **Match** A clinician is matched to a placement only when licence, credential and registration status actually cover that facility and those dates.
2. **Start** Credentialing progress is tracked against the start date, so an incomplete file is visible while there is still time to complete it.
3. **Maintain** Expiries are watched across the assignment rather than at onboarding, because assignments routinely outlast a renewal cycle.

## From the source material

> Also, a physician who has left the group and for whom the group has engaged a locum tenens physician as a temporary replacement may bill for the temporary physician for up to 60 days.

Source: CMS, claims processing transmittal, https://www.cms.gov/regulations-and-guidance/guidance/transmittals/downloads/r1486cp.pdf

## Industry context

- **30,000** One estimate cited by DEA put the number of locum tenens practitioners in the United States above 30,000. (source: DEA rulemaking record, https://downloads.regulations.gov/DEA-2009-0012-0001/content.htm)
- **100 agencies** The same estimate put the number of locum tenens agencies operating nationally at more than 100. (source: DEA rulemaking record, https://downloads.regulations.gov/DEA-2009-0012-0001/content.htm)
- **1301.13** The registration period for persons who dispense controlled substances is set by regulation at three years. (source: DEA rulemaking record, https://downloads.regulations.gov/DEA-2009-0012-0001/content.htm)
- **0.100** Authority to issue controlled substance registrations is delegated to the DEA Administrator by regulation. (source: DEA rulemaking record, https://downloads.regulations.gov/DEA-2009-0012-0001/content.htm)
- **2006** A 2006 final rule specified that only intrastate locations fall within the exception to separate registration. (source: DEA rulemaking record, https://downloads.regulations.gov/DEA-2009-0012-0001/content.htm)

## Pricing

- Small agency: $160 per month
- Agency: $420 per month
- Enterprise: $840 per month

## Questions

### What is locum tenens staffing?

It is the placement of clinicians into temporary assignments covering a vacancy, a leave or a seasonal gap. Agencies recruit and place the clinicians, facilities retain them, and state regulatory authorities govern the licensure that makes the work lawful. The staffing part is logistics. The part that decides whether an assignment can actually begin is whether licensure, credentialing and any required registration are all in place for that clinician at that facility.

### How big is the locum tenens market?

Larger than most people assume. In examining how registration rules apply to temporary practitioners, DEA cited an estimate of over 100 locum tenens agencies operating in the United States and more than 30,000 locum tenens practitioners. The specialities most in demand were hospital based, including anaesthesiology, psychiatry, radiology, paediatrics and surgery.

### Does a clinician's registration travel with them?

Not straightforwardly, and this is the crux of the issue. Registration to dispense controlled substances is obtained in relation to a principal place of business or professional practice, and a later final rule specified that only intrastate locations fall within the exception to obtaining a separate registration. For a clinician moving between facilities, and particularly across state lines, the question has to be answered per placement rather than once per person.

### What do federal site visits examine?

Clinical staffing is one of the areas reviewed, including how an organisation assures that its clinicians hold the licences and credentials their roles require. Because locum clinicians are placed quickly and often start under time pressure, they are exactly where an otherwise sound credentialing process tends to show gaps.

### Is the software available now?

No. It is in development and open for early access. We are building the placement level compliance record with agencies that place across state lines.

## Sources

- [DEA, registration requirements for practitioners operating in a locum tenens capacity](https://downloads.regulations.gov/DEA-2009-0012-0001/content.htm)
- [HRSA, site visit protocol, clinical staffing](https://bphc.hrsa.gov/compliance/site-visits/site-visit-protocol/clinical-staffing)
- [HRSA, health center compliance manual chapter 5](https://bphc.hrsa.gov/compliance/compliance-manual/chapter5)
- [42 CFR 411.357, exceptions to the physician referral prohibition](https://www.law.cornell.edu/cfr/text/42/411.357)
- [CMS, claims processing transmittal](https://www.cms.gov/regulations-and-guidance/guidance/transmittals/downloads/r1486cp.pdf)

## Contact

- office@neurobird.com
- https://neurobird.com/