Anesthesia Coding Alert

Question: Our CRNAs are employed by the hospital. They sometimes perform supplemental procedures such as A-line or CVP insertions under the medical direction of our attending anesthesiologist. I understand this falls under the medical direction guidelines as part of the entire anesthesia plan. However, an external auditing company says that we should be billing these procedures under the CRNA’s name and not the attending, even though the attending was present in the OR at the time of the procedure and has met other medical direction requirements. How should we handle this? De we pull those procedures off the attending’s chart and submit a claim for the CRNA’s services? Or do we submit it all under the attending as part of the full scope of anesthesia services?

Oregon Subscriber

Answer: The auditors are correct. If you have been billing CRNA services under the attending anesthesiologist, you’re essentially billing their services as “incident-to,” which under CMS rules is not allowed in a facility setting.

Here’s why: In a facility, all professional services must be billed under the credentials of the provider who actually performs the work. By billing CRNA services under the physician’s credentials, Medicare would reimburse these claims at 100 percent of the fee instead of the 85 percent, which would be the correct rate for a mid-level provider. You have likely been overpaid for your CRNA services and will need to reimburse Medicare for these overpayments. If that is the case, you will need to act quickly on this since it has been brought up by your auditors and you may be under a time requirement to refund these payments to Medicare from the date that this was identified.

A common mistake made by physicians is presuming that because the CRNA is medically directed, so are the services they provide. This is not true as we have indicated. Surgical procedures such as an arterial line cannot be “medically directed” as they are not anesthesia.