Anesthesia Coding Alert

Question: Can an anesthesiologist direct one CRNA and be the anesthesia provider for a separate concurrent case if the CRNA is an independent contractor?

Arizona Subscriber

Answer: Probably not. Regardless of whether the CRNA is employed by the practice or an independent contractor, the anesthesiologist cannot medically direct and personally perform anesthesia services at the same time, except for a few allowable activities. This is true for any payer that follows the Centers for Medicare & Medicaid Services (CMS) guidelines, which indicate the following:

“A physician who is concurrently furnishing services that meet the requirements for payment at the medically directed rate cannot ordinarily be involved in furnishing additional services to other patients. However, addressing an emergency of short duration in the immediate area, administering an epidural or caudal anesthetic to ease labor pain, periodic (rather than continuous) monitoring of an obstetrical patient, receiving patients entering the operating suite for the next surgery, checking or discharging patients in the recovery room, or handling scheduling matters, do not substantially diminish the scope of control exercised by the physician and do not constitute a separate service for the purpose of determining whether the requirements for payment at the medically directed rate are met.”

Resource: Review the CMS guidance at www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c12.pdf.