If the service was personally performed by the CRNA then the QZQS (in this order) are the appropriate modifiers. However, per the CMS Website, California is NOT an opt out state. If so this means services performed in California by a CRNA cannot be performed without medical direction or supervision and based on this information, the QZ modifier would not be appropriate. Instead the modifiers for this service would be QXQS. In addition, there is a 50% fee schedule reduction for the QX modifier. I do not have specific California CRNA licensure limitiation so I strongly urge you to confirm the opt out information with your provider, another CA CRNA anesthesia practice, and/or Palmetto. I have attached some references below.
Palmetto anesthesia modifier link:
CMS CRNA opt out info per CMS Website:
CMS established an exemption for Certified Registered Nurse Anesthetists (CRNAs) from the physician supervision requirement by recognizing a Governor's written request to CMS attesting that he or she is aware of the State's right to an exemption of the requirement and it is in the best interests of the State's citizens to exercise this exemption on November 13, 2001.
At this time, fourteen states have chosen to opt-out of the CRNA physician supervision regulation. Those states are: Iowa, Nebraska, Idaho, Minnesota, New Hampshire, New Mexico, Kansas, North Dakota, Washington, Alaska, Oregon, South Dakota, Wisconsin and Montana.
Hope this helps.
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