Anesthesia Business Consultants Alerts Anesthesiologists that the OIG Targets “Personally Performed” Anesthesiologist Services
<0> Anesthesia Business ConsultantsTony Mira, 517-787-6440Email: </0>
The OIG’s Work Plan for 2013, released last week, includes a new anesthesia item on the list of issues to be studied. This item— “Anesthesia Services–Payments for Personally Performed Services”—is not one with which ABC has encountered difficulties or controversies. It has been the Medicare rule for many years that an anesthesiologist who performs a case working with a qualified nurse anesthetist or anesthesiologist assistant should report a “medical direction” or “supervision,” not personal performance.
We are treating this unusual appearance of an issue that refers to medical direction by an anesthesiologist in the OIG Work Plan as a wake-up call, however. There are—despite the best efforts of Medicare staff and dozens if not hundreds of compliance experts over the years—still questions as to how to report and bill for an anesthetic that does not clearly fit one or the other of the “care team” modifier codes. One of these questions arises when an anesthesiologist and a CRNA are involved in a single case at the end of the day.
When all the other cases have finished, the anesthesiologist involved in that final case of the day lets the CRNA go home, because the MD can now personally perform the anesthetic just as easily as he or she can continue to medically direct the single CRNA in the operating room suite. There is no way to report this common scenario correctly using the Medicare system, which does not recognize that the anesthesiologist’s function may shift from directing a CRNA to working alone in any particular case.
Now that “personal performance” and “medical direction” are on the OIG’s radar, ABC will be checking with Medicare regional offices and contractors to obtain clarification as to acceptable ways to bill cases that start out as medically directed and finish as personally performed by the anesthesiologist.
ABC, established in 1979, is the nation’s largest billing and practice management companies dedicated to the complex and intricate specialty of anesthesia and pain management. It is both an American Society of Anesthesiologists Practice Management Supporter, and an Anesthesia Quality Institute Preferred Vendor. It has also successfully completed a Service Organization Controls (SOC) 1 Report, which is an independent third-party verification of a company’s internal operational controls and processes. ABC employs industry leaders, operates under proven efficient processes, and utilizes technology advances to easily adapt to the ever-changing regulatory environment. Visit ABC at: .