Anesthesia Coding Alert

Reader Question:

Avoid Appending -GC for SRNAs Directed by Doctors

Question: Can you provide guidance on how to bill for student registered nurse anesthetists (SRNAs) and what modifier(s) to use? Our doctors direct student nurses, no more than two at a time. When billing Medicare, we have been using -QK for these scenarios, but we are only getting reimbursed at 50 percent. Could we use -AA and -GC and get reimbursed at 100 percent?

Florida subscriber

Answer: Absolutely not! When the doctors are directing SRNAs, stick to medical direction modifiers such as -QK (Medical direction of two, three, or four concurrent anesthesia procedures involving qualified individuals). You should only append -AA (Anesthesia services performed personally by anesthesiologist) and -GC (This service has been performed in part by a resident under the direction of a teaching physician) when the anesthesiologist is supervising a physician resident, not an SRNA. Medicare does not pay for the student nurse’s services, although the anesthesiologist is paid for their work at 50 percent of the allowed amount.

However, if your certified registered nurse anesthetists (CRNAs) are the ones teaching, Medicare allows them to be paid for 100 percent of the time they spend with each student nurse, providing the documentation supports the following:

“If the teaching CRNA, who is not under the medical direction of a physician, is involved in two concurrent student nurse anesthetist cases, payment could be made based on the full base units and partial time units. To bill the base units, the teaching CRNA must be present with the student nurse anesthetist during the pre and post anesthesia care for each of the two cases involving student nurse anesthetists” (www.cms.gov/regulations-and-guidance/guidance/transmittals/downloads/r1859cp.pdf).