Anesthesia Coding Alert

Question: I’m relatively new to anesthesia coding and am having a hard time understanding what criteria must be met before a case can be considered as “medical direction” instead of “medical supervision,” per the Centers for Medicare & Medicaid Services (CMS). Are you able to help?

Arizona Subscriber

Answer: Medical direction is a term that is used when an anesthesiologist is overseeing the administration of anesthesia by up to four trained nonphysician anesthesia providers simultaneously. Before a case can be classified as medical direction rather than medical supervision, it must meet seven specific criteria, as outlined by CMS. These seven criteria are sometimes referred to as the seven steps of medical direction.

To qualify as medical direction, the anesthesiologist must:

1. Perform a pre-anesthesia examination and evaluation
2. Prescribe an anesthesia plan
3. Personally participate in the most demanding procedures of the anesthesia plan, including induction and emergence
4. Ensure that a qualified anesthetist performs any procedures in the anesthesia plan that the anesthesiologist does not personally perform
5. Monitor the course of anesthesia administration at intervals
6. Remain physically present for all critical portions of the procedure and be available for immediate diagnosis and treatment of emergencies
7. Provide post-anesthesia care as indicated

Your modifier choices to designate when an anesthesiologist medically directed a case are:

• QY (Medical direction of one certified registered nurse anesthetist (CRNA) by an anesthesiologist)
• QK (Medical direction of two, three, or four concurrent anesthesia procedures involving qualified individuals)

Key takeaways: An anesthesiologist is allowed to be involved in more than one concurrent case as long as they are not the one personally administering the anesthesia. Medical direction is often associated with a higher reimbursement than medical supervision, but it involves meeting more rigorous requirements before it can be reported on a claim.

Lindsey Bush, BA, MA, CPC, Production Editor, AAPC