# CRNA's and the TC for EMG's



## clgregory (Nov 2, 2012)

I have been asked the following question and am looking for help:

Can a CRNA bill the technical component for EMG's? (95885-95887, 95900-95905)

I am not sure why a CRNA would want to but if anyone has had experience with this or can give me an answer, I would greatly appreciate your assistance.  I have already researched this on the CMS website and have found the area that states what extra procedures anesthesiologists can bill but did not know if there was anything further.

Thank you.


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## SJordan (Nov 2, 2012)

*CRNA and TC*

RED FLAG !! 
Why would a CRNA be participating in a procedure??
What happened to the technician??  
Unless the CRNA actually performed the TC portion 
of the code, he/she cannot charge for the procedure.


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## clgregory (Nov 2, 2012)

*CRNA and TC*

That was my response and evidently there is a CRNA that is "wanting" to perform an EMG but my thought also was that it would be out of their scope of practice.


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## mitchellde (Nov 2, 2012)

before you get in this any further you are going to want to check your new 2013 CPT book as the guidelines/requirements, and codes have changed dramatically for 2013 and your answers may be there.


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## dwaldman (Nov 4, 2012)

Are you referring to a baseline study for neurophysiological monitoring? Like Michelle said usually a technican is providing the performance of the service and then starts the recording for the neruomonitoring. Then an physician monitors remotely. The technicans have training and credentials to perform the aspects they are performing. They would additionally have priveldges at the facility to perform this.  Currently codes such as 95920, 95870, 95938 are types of codes that are reported. In 2013, option will be 95940, 95941, and for Medicare G0453 will be reported. In the 2013 AMA CPT manual, it states that neither the surgeon nor the anesthesiologist may report the neuromonitoring  codes. 

Below is from Medicare final rule, it describes what is the CRNA is allowed to per the state they are in. Would need to confirm that state you are in recognizes CRNA to be able to perform electromyography and if the facility would consider granting priviliges to the CRNA to perform. If the state will not allow or the facility will not allow then doesn't look like it would be an option.

www.ofr.gov/inspection.aspx

Page 371

Certified Registered Nurse Anesthetists Scope of Benefit
The benefit category for services furnished by a certified registered nurse anesthetist (CRNA) was added in section 1861(s)(11) of the Act by section 9320 of the Omnibus Budget Reconciliation Act (OBRA) of 1986. Since this benefit was implemented on January 1, 1989, CRNAs have been eligible to bill Medicare directly for services within this benefit category.  Section 1861(bb)(2) of the Act defines a CRNA as “a certified registered nurse anesthetist
licensed by the State who meets such education, training, and other requirements relating to anesthesia services and related care as the Secretary may prescribe. In prescribing such requirements the Secretary may use the same requirements as those established by a national organization for the certification of nurse anesthetists.” Section 410.69(b) defines a CRNA as a registered nurse who: (1) is licensed as a registered professional nurse by the State in which the nurse practices; (2) meets any licensure requirements the State imposes with respect to nonphysician anesthetists; (3) has graduated from a nurse anesthesia educational program that meets the standards of the Council on Accreditation of Nurse Anesthesia Programs, or such other accreditation organization as may be designated by the Secretary; and (4) meets one of the following criteria: (i) has passed a certification examination of the Council on Certification of Nurse Anesthetists, the Council on Recertification of Nurse Anesthetists, or any other certification organization that may be designated by the Secretary; or (ii) is a graduate of a program described in paragraph (3) of this definition and
within 24 months after that graduation meets the requirements of paragraph (4)(i) of this definition.  Section 1861(bb)(1) of the Act defines services of a CRNA as “anesthesia services and related care furnished by a certified registered nurse anesthetist (as defined in paragraph (2)) which the nurse anesthetist is legally authorized to perform as such by the State in which the
services are furnished.” CRNAs are paid at the same rate as physicians for furnishing such services to Medicare beneficiaries. Payment for services furnished by CRNAs only differs from physicians in that payment to CRNAs is made only on an assignment-related basis (§414.60) and supervision requirements apply in certain circumstances.  At the time that the Medicare benefit for CRNA services was established, anesthesia practice, for anesthesiologists and CRNAs, largely occurred in the surgical setting and services other than anesthesia (medical and surgical) were furnished in the immediate pre- and postsurgery timeframe. The scope of “anesthesia services and related care” as delineated in section 1861(bb)(1) of the Act reflected that practice. As anesthesiologists and CRNAs have moved into
other practice settings, questions have arisen regarding what services are encompassed under the benefit category's characterization of “anesthesia and related care.” As an example, some CRNAs now offer chronic pain management services that are separate and distinct from a
surgical procedure. We recently received additional information about upcoming changes to CRNA curricula to include specific training regarding chronic pain management services. Such changes in CRNA practice have prompted questions as to whether these services fall within the
scope of section 1861(bb)(1) of the Act.  As we noted in the CY 2013 proposed rule (77 FR 44788), Medicare Administrative Contractors (MACs) have reached different conclusions as to whether the statutory benefit
category description of “anesthesia services and related care” encompasses the chronic pain management services furnished by CRNAs. The scope of the benefit category determines the scope of services for which a physician, practitioner, or supplier may receive Medicare payment.  In order for the specific services to be paid by Medicare, the services must be reasonable and
necessary for treatment of the patient's illness or injury.  To address what is included in the benefit category for CRNAs in the CY 2013 proposed rule, we assessed our current regulations and subregulatory guidance, and determined that the existing guidance does not specifically address whether chronic pain management is included in the CRNA benefit. In the Internet Only Manual (Pub 100-04, Ch 12, Sec 140.4.3), we discuss the medical or surgical services that fall under the “related care” language stating: “These may
include the insertion of Swan Ganz catheters, central venous pressure lines, pain management, emergency intubation, and the pre-anesthetic examination and evaluation of a patient who does not undergo surgery.” Some have interpreted the reference to “pain management” in this language as authorizing direct payment to CRNAs for chronic pain management services, while others have taken the view that the services highlighted in the manual language are services furnished in the perioperative setting and refer only to acute pain management associated with the surgical procedure. 371 After assessing in the proposed rule (see 77 FR 44788) the information available to us, we concluded that chronic pain management was an evolving field, and we recognized that certain states have determined that the scope of practice for a CRNA should include chronic pain management to meet health care needs of their residents and ensure their health and safety. We also found that several states, including California, Colorado, Missouri, Nevada, South Carolina, and Virginia, were debating whether to include pain management in the CRNA scope of practice.  After determining that the scope of practice for CRNAs was evolving and that there was not a
clear answer on pain management specifically, we proposed to revise our regulations at §410.69(b) to define the statutory benefit for CRNA services with deference to state scope of practice laws. Specifically, we proposed to add the following language: “Anesthesia and related care includes medical and surgical services that are rel ted to anesthesia and that a CRNA is
legally authorized to perform by the state in which the services are furnished.” We explained that this proposed definition would set a Medicare standard for the services that can be furnished and billed by CRNAs while allowing appropriate flexibility to meet the unique needs of each state. The proposal also dovetailed with the language in section 1861(bb)(1) of the Act requiring the state's legal authorization to furnish CRNA services as a key component of the CRNA benefit category. Finally, we stated that the proposed benefit category definition was also consistent with our policy to recognize state scope of practice as defining the services that can be
furnished and billed by other NPPs.


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