|
 |
| Medicare Reimbursement Guidelines for Anesthesiology Services Performed Concurrently with Medical Direction – Q & A |
Andrew Bloschichak, M.D., MBA 1
The specific duties an anesthesiologist may perform concurrently while medically directing nurse anesthetists, and still seek Medicare reimbursement as medical direction, have been the subject of questions and controversy for at least twenty years. Therefore, the following is an attempt to answer some common questions and to provide a reasonable interpretation of the existing CMS regulations regarding medical direction, consistent with current anesthesia practices in the state of Pennsylvania. The general guidelines for concurrent services which may be performed along with medical direction are outlined in the Medicare Claims Processing Manual, Publication 100-4, Chapter12, Section 50C: A physician who is concurrently directing the administration of anesthesia to not more than four surgical patients cannot ordinarily be involved in furnishing additional services to other patients. However, addressing an emergency of short duration in the immediate area, administering an epidural or caudal anesthetic to ease labor pain, or periodic, rather than continuous, monitoring of an obstetrical patient does not substantially diminish the scope of control exercised by the physician in directing the administration of anesthesia to surgical patients. It does not constitute a separate service for the purpose of determining whether the medical direction criteria are met. Further, while directing concurrent anesthesia procedures, a physician may receive patients entering the operating suite for the next surgery, check or discharge patients in the recovery room, or handle scheduling matters without affecting fee schedule payment. However, if the physician leaves the immediate area of the operating suite for other than short durations or devotes extensive time to an emergency case or is otherwise not available to respond to the immediate needs of the surgical patients, the physician’s services to the surgical patients are supervisory in nature. Carriers may not make payment under the fee schedule This section provides both general guidelines for allowable concurrent services and an illustrative list of services which, in the opinion of CMS, meet these guidelines. These general guidelines, however, do raise significant questions from anesthesiologists, including the following: Question: What guideline should a provider use to determine whether a specific service can or cannot be provided at the same time as medical direction? Answer: The above guidelines advise that a physician who is providing medical direction of anesthesia care cannot ordinarily provide additional services to other patients. However, these guidelines also describe the type of services that the physician may provide, if the services do not prevent the physician from being immediatelyavailable to respond to the needs of the surgical patients. Question: May an anesthesiologist perform preoperative evaluations for patients presenting for surgery later that day, or on future days? Answer: Yes. A s long as the area in which the evaluations are performed is easily accessible from any area of the operating suite, the patient services do not prevent the physician from being immediately available to address emergencies in the operating room, and most importantly, “do not substantially diminish the scope of control exercised by the physician in directing the administration of anesthesia to surgical patients,” the anesthesiologist may perform pre-operative examinations concurrently while directing anesthesia care. Question: May an anesthesiologist perform procedures on patients presenting for surgery that day, either preoperatively or in the post anesthesia care unit? Answer: An anesthesiologist may perform, and if otherwise eligible seek reimbursement for, procedures (such as arterial line insertions, central venous catheter insertions, pulmonary artery catheter insertions, and epidural, spinal, and peripheral nerve blocks) in an area that is immediately available to the OR, and when the performance of such services do not prevent him/her from being immediately available to respond to the needs of the surgical patients. Question: What constitutes the “immediate area of the operating suite”? Answer: Differences in the geographic design and size of facilities, differences in the severity of illness, and the complexity and demands of the particular surgical procedures make this distance impossible to universally define. This said, the anesthesiologist must remain close enough to the operating room to return to the operating room, if/when needed, in time to meet the needs of the patient, and most importantly, emergencies that may arise.
1 Dr. Bloschichak is the Vice President and Contractor Medical Director for Highmark Medicare Services, Pennsylvania’s Medicare Carrier 2 Drs. West and Martin are the Representatives from Anesthesiology to Pennsylvania’s Medicare Carrier Advisory Committee
|
|
|