Anesthesia Coding Alert

Question: I code for an ASC that employs CRNAs. The ASC is in New York, which requires all CRNAs to be supervised. The state requires the supervision be by a physician, but does not specify which type of physician it must be. In this center, GI physicians performing endoscopies supervise the CRNAs. They are not directed by an anesthesiologist. Is it still appropriate for us to append modifier QZ to the CRNA claims even though the GI physician is taking responsibility instead of an anesthesiologist?  

New Jersey Subscriber 

Answer: Yes, you should still include modifier QZ (CRNA service: without medical direction by a physician) on the CRNA’s claims. 

Rationale: The CRNA is being supervised rather than medically directed, which is one criteria for modifier QZ. In addition, if you bill the CRNA’s claim with modifier QX (CRNA service: with medical direction by a physician), the payer will look for an accompanying claim with either modifier QY (Medical direction of one certified registered nurse anesthetist [CRNA] by an anesthesiologist) or QK (Medical direction of two, three, or four concurrent anesthesia procedures involving qualified individuals) for the anesthesiologist’s service. That isn’t possible in this situation because you aren’t coding for an anesthesiologist and the GI physician cannot submit claims for both anesthesia and the procedure.