Anesthesia Coding Alert

Other news: Don’t miss your chance at $39,000 if you still haven’t joined the EHR incentive program.

The Centers for Medicare & Medicaid Services (CMS) released the calendar year 2014 Medicare physician fee schedule proposed rule on July 8, which outlines possible changes to policies and payment rates for services rendered on and after January 1, 2014. If the proposed rule stands, it could have a positive impact on anesthesia providers’ reimbursement.  

The proposed rule includes a summary of the estimated impact changes would have on allowed charges, broken down by specialty. The impact on anesthesia would be a positive 3 percent.  

Note: The proposed rule assumes the Medicare Sustainable Growth Rate (SGR) cut of 24.4 percent (scheduled to go into effect at the end of 2013) occurs. In previous years, Congress has passed an "SGR Fix" as a standalone bill or as part of a legislative package to avoid the SGR cuts. 

The comment period on the proposed rule is open for 60 days from the date it is published in the Federal Register. To review the rule and associated documents, visit www.cms.gov and search for "2014 Medicare Proposed Physician Fee Schedule."

EHR Incentive Program Deadline Looms Near

The deadline is fast approaching for anesthesiologists, pain physicians, and other eligible professionals (EPs) to begin documenting meaningful use of their electronic health record (EHR) technology for 2013. EPs must begin participating in the program by October 3, 2013, and continue for 90 days (through Dec. 31, 2013) to earn an incentive bonus of up to $15,000.

The incentive payment is 75 percent of Medicare allowed charges up to a maximum annual cap. A provider who first demonstrates meaningful use in 2013 can earn a maximum incentive of $39,000 over four years. If a provider waits until 2014 to begin participating in the program, the maximum payment will be $24,000.

Warning: 2014 is the last year to initiate 90-day reporting periods to qualify for future incentives. The EP must successfully show meaningful use by 2014 or face financial penalties beginning in 2015. Penalties will be assessed by deducting increasing amounts from Medicare payments the provider would normally receive for services.

"One question that comes up repeatedly is whether the EEHR incentive program has any applicability to anesthesiologists," Tony Mira, president and CEO of Anesthesia Business Consultants in Jackson, Mich., wrote in a recent update. "Hospital-based physicians are not eligible for incentive payments … The majority of anesthesiologists provide more than ten percent of their services on an outpatient basis or in ambulatory surgical centers. If they do, they are eligible for the incentive payment – and potentially subject to the penalty for nonparticipation."

Some anesthesiologists fall under a "hardship exemption" because they must use EHR technology selected by others and aren’t able to avoid penalties by making meaningful use of certified EHR systems. CMS determines whether the hardship exemption applies on a case-by-case basis.

"The availability of the hardship exemption does not exclude anesthesiologists from the EEHR incentive program," Mira notes. "Receiving an incentive would override the automatic hardship exemption."

Bottom line: It’s not too late to join the EHR incentive program, and the potential incentives make the effort worthwhile for many practices. To get the latest news on the program, visit www.cms.gov and search for "EHR incentive program."

Change Could Come to Rural Hospital Anesthesia Incentive Program

Senators Ron Wyden (D-OR) and Johnny Isakson (R-GA) of the U.S. Senate Finance Committee, introduced S. 1444 on August 1, known as the "Medicare Access to Rural Anesthesiology Act of 2013." The legislation calls for taking steps to reform the current Medicare rural anesthesia incentive program to include physician anesthesiologists.

Background: CMS usually pays for anesthesia services based on the Medicare Part B fee-for-service payment schedule. However, low Part B payment levels and low patient volume make attracting and retaining anesthesia providers difficult for some rural hospitals. Congress responded to the situation by creating a special program that allows certain small rural hospitals to receive reasonable cost-based Part A payments for the services of anesthesiologist assistants and nurse anesthetists. The program (the Medicare Anesthesia Rural Pass-Through program) is meant to offer rural facilities the incentive to continue serving Medicare beneficiaries in their area.  

Possible change: The current pass-through program excludes hospitals using physician anesthesiologists from participation. The Wyden-Isakson legislation grants rural hospitals more flexibility to use the services of physician anesthesiologists, in addition to AAs and nurse anesthetists.