Medicare Compliance & Reimbursement

Meet these 7 criteria and you’re on your way to QY or QZ success.

Before you can code medical direction for anesthesia services during surgery, the anesthesiologist must document his or her presence during all critical or key portions of the procedure. The anesthesiologist must:

• perform a pre-anesthesia examination and evaluation;
• prescribe an anesthesia plan;
• personally participate in the most demanding procedures of the anesthesia plan, including induction and emergence;
• ensure that any procedure in the plan that he or she does not perform is performed by a qualified anesthetist;
• monitor the course of anesthesia administration at intervals;
• remain physically present and available for immediate diagnosis and treatment of emergencies;
• provide the indicated post-anesthesia care.

Note: Some payers (such as Palmetto GBA) state that the anesthesiologist must be present for induction and emergence when necessary, but allow some leeway with this section of the criteria. Palmetto’s policy reads, “Personally participates only in the most demanding procedures of the anesthesia plan, including, if applicable, induction and emergence.”

If you verify all of the criteria, the anesthesiologist has met what’s known as the seven rules of medical direction. You’ll report the anesthesiologist’s work 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), depending on the number of concurrent cases he directs.