Anesthesia Payment Policy Revised for 2010

Anesthesiologists and certified registered nurse anesthetists (CRNAs) who bill Medicare for teaching anesthesia services to residents and student nurse anesthetists should be aware of a payment policy change that will go into effect the first of the year.

The Centers for Medicare & Medicaid Services (CMS) is implementing section 139 of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA); and has revised and replaced section 16003 “Anesthesia Services and Teaching CRNAs” in the paper-based publication 14, The Carriers Manual, Part 3- Claims Process, with new section 140.5.

Anesthesiologist Payment Policy

CMS is establishing a special payment rule for teaching anesthesiologists and specifying the periods when a teaching anesthesiologist must be present during a procedure to receive payment for the case at 100 percent of the anesthesia fee schedule amount.

Effective for services furnished on or after Jan. 1, payment may be made to a qualified teaching anesthesiologist under the Medicare Physician Fee Schedule (MPFS), at the regular fee schedule amount, for training residents in a single anesthesia case, two concurrent cases, or in a single case that is concurrent to another case paid under the medical direction rules.

For this special payment rule to apply: 1) The teaching anesthesiologist (or different anesthesiologists in the same physician group) must be present during all critical or key portions of the anesthesia service; 2) If a different teaching anesthesiologists in the anesthesia group are present during the key or critical periods, the performing physician (for purposes of claims reporting) is the teaching anesthesiologist who started the case; and 3) The teaching anesthesiologist (or another anesthesiologist with whom the teaching anesthesiologist has entered into an arrangement) must be immediately available to furnish anesthesia services during the entire procedure.

The patient’s medical record documentation must indicate the teaching physician’s presence during all critical or key portions of the anesthesia procedure and the immediate availability of another teaching anesthesiologist as necessary.

CRNA Payment Policy

Section 140.5 reiterates that a teaching CRNA (not under the medical direction of a physician) can be paid at the regular fee schedule amount under Medicare Part B when continuously present and supervising a single case involving a student nurse anesthetist.

For services furnished on or after Jan. 1, the teaching CRNA, not under the medical direction of a physician, can be paid for his/her involvement in each of two concurrent cases with student nurse anesthetists at 50 percent the regular fee schedule rate.

A teaching CRNA can also be paid when involved with two student nurse anesthetists and the service is furnished on or after Aug. 1, 2002. Contractors will recognize the full base units (assigned to the anesthesia code) when the teaching CRNA is present with the student nurse anesthetist throughout pre and post anesthesia care; and the actual time the teaching CRNA is personally present with the student nurse anesthetist. Anesthesia time may be discontinuous.

Payment Modifiers

Teaching anesthesiologists and CRNAs should continue to report their anesthesia services using the existing anesthesia payment modifiers.

The teaching anesthesiologist should use modifier AA Anesthesia services performed personally by anesthesiologist and modifier GC The teaching physician was present during the key portion of the service and was immediately available during other parts of the service to report such cases. The CRNA should use the usual modifier QZ CRNA service: without medical direction by a physician to report such cases or modifier QX with medical direction.

Read CMS Transmittal 1859, issued Nov. 20, for complete details. MLN Matters MM6706 is also available on the CMS Web site.

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