Anesthesia Coding Alert

Reader Questions:

Master Medical Direction and Modifiers

Question: I would like to confirm how many residents an anesthesiologist can medically direct at the same time, what the documentation requirements are, and which modifiers I should report. Also, are the modifiers reported to all payers?

Indiana Subscriber

Answer: In a teaching facility, an anesthesiologist is allowed to medically direct either one or two residents. Whether teaching one or two residents, report these modifiers to Medicare:

  • AA (Anesthesia services performed personally by anesthe­siologist)
  • GC (This service has been performed in part by a resident under the direction of a teaching physician)

Although Medicare requires these modifiers, not all payers do. For instance, in some states, Medicaid may reject modifier GC. It is important that your payment department and coders have open communication to ensure proper use of the modifiers. If a particular payer denies or reduces payment for reporting modifier GC, contact the payer to determine the reason for the reduction. Stop reporting the modifier if the payer does not recognize it.

NPI tip: Medicare also has special rules for when to use the physician’s National Provider Identifier (NPI). “The teaching anesthesiologist who started the case and stayed with the resident during critical or key service and procedure parts (with different anesthesiologists present), must include their NPI on the claim,” according to the Medicare booklet Teaching Physicians, Interns, & Residents Guidelines (www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/teaching-physicians-fact-sheet-icn006437.pdf).

According to Medicare, documentation must sufficiently describe the specific services furnished to the specific patient on the specific date. The critical and key portions of anesthesia are induction, emergence, and any patient interaction that requires the attending physician’s oversight.


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