Anesthesia Coding Alert

Reader Questions:

Meet the “7 Rules” Before Reporting Medical Direction

Question: I’m new to anesthesia coding. Can you explain the medical direction “rules” I’ve been told to follow?

Arizona Subscriber

Answer: When anesthesiologists work with other qualified anesthesia providers, such as certified registered nurse anesthetists (CRNA) and anesthesia assistants (AA), they must follow special documentation requirements to be paid for their involvement in the case.

The medical direction rules (which are sometimes referred to as the “7 rules of medical direction”) apply when an anesthesiologist works with one to four other qualified providers in overlapping cases. The anesthesiologist must meet all of these criteria in addition to documentation requirements in order to report a case as medically directed:

1. Perform a pre-anesthetic examination and evaluation.

2. Prescribe the anesthesia plan.

3. Personally participate in the most demanding procedures in the anesthesia plan, including (if applicable) induction and emergence.

4. Ensure a qualified individual performs any procedures in the anesthesia plan that the anesthesiologist does not personally perform.

5. Monitor the course of anesthesia administration at frequent intervals.

6. Remain physically present for all key and critical portions of the procedure, and be available for immediate diagnosis and treatment of emergencies.

7. Provide post-anesthesia care as indicated.

Important: If more than four cases overlap — even for a single minute — this is considered to be medical supervision rather than medical direction. Most payers reduce payment to the anesthesiologist for cases classified as medical supervision. The rules also may be different in teaching hospitals, where residents are involved in patient care.

Tip: Check to see if your state Medicare Administrative Contractor has published Frequently Asked Questions (FAQS) for medical direction. Interpretation of broken medical direction varies from state to stat


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