Weekly eAlerts Covering Regulatory Changes, Compliance Reminders &
Other Changes in the Anesthesia Industry

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Anesthesia Industry eAlerts

Sent to subscribers every Monday morning, our eAlerts deliver timely updates on regulatory, legislative and practice management developments of interest to anesthesia professionals.

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eAlerts

  • A Disturbing Proposal: CMS Releases 2022 Proposed Anesthesia Fee Schedule

    July 19, 2021

    Some suggestions can be rather upsetting, and some recommendations can be downright discouraging.  Such is the case for the proposals coming out of the Centers for Medicare and Medicaid Services (CMS) this month—at least in the eyes of many in the healthcare community.  On July 13, CMS released its 2022 Medicare Physician Fee Schedule (PFS) Proposed Rule (PR).  This 1,747-page document addresses topics from teaching guidelines to telehealth services, along with many others.  It represents the government’s current thinking on what next year’s Medicare requirements and reimbursement rates should look like.  It’s not set in stone, but the mortar is hardening. 

  • A Higher Hurdle: Anesthesia for Facets Faces Uphill Battle

    July 12, 2021

    From the crease of the valley below, you can see the degree of the slope just ahead.  The walk thus far has been at either a level grade or a downward tilt.  Now, greater energy must be expended as the road begins angling upward, with an even more exaggerated incline toward the top.  The task looks so daunting, you begin to wonder if it’s worth the effort. 

  • How Will the New Federal Surprise Billing Law Impact Anesthesia Reimbursement?

    July 6, 2021

    A 2018 study from the Kaiser Foundation suggested that 18 percent of inpatient visits in participating facilities received care from a non-participating provider, resulting in a surprise bill. The source of the out-of-network (OON) care could have included any provider type, and in fact the highest incidence of OON care in that study was not attributed to physicians at all, but to medical transport providers. The idea of legislation limiting patient balances from out-of-network care has long had bipartisan support, but lawmakers struggled with the appropriate model to address the issue. After several years of political wrangling, the “No Surprises Act” was included in the year-end stimulus bill from December of 2020. The law applies to surprise billing not addressed by existing state laws. Starting in January of 2022, the bill limits OON patient balance billing to co-payments and deductible as defined by the member’s in-network plan benefit.

  • Changes to Provider Relief Fund Requirements: What This Means for Anesthesia

    June 28, 2021

    Sometimes, we receive good news.  In a year dominated by distressing stories of mass illness and protracted lockdowns and financial strains, it’s refreshing to hear something that provides a modicum of stress relief.  You’ll recall that the federal government enacted a series of laws, beginning last year, to mitigate the financial impact of the COVID pandemic on healthcare providers.  Among these were the Coronavirus Aid, Relief, and Economic Security (CARES) Act; the Paycheck Protection Program and Health Care Enhancement Act; and the Coronavirus Response and Relief Supplemental Appropriations Act of 2021.  While these laws made billions of dollars available to providers experiencing lost revenues attributable to COVID, the money did not come without a few conditions.

  • The Evolution of Anesthesia Care for Total Hips

    June 21, 2021

    As the premier provider of outsourced billing and management information to anesthesia practices nationwide, we constantly monitor changes in production, performance and profitability for our clients.  As significant developments unfold, we are always trying to assess their strategic and financial impact.  While many coding and payer policy changes may prove to be relatively insignificant, more often than not there are underlying market factors that may be of consequence to the ongoing viability and success of our client practices.  We are of the belief that forewarned is fore-armed.

  • Before and After: An Analysis of Pre- and Post-Anesthesia Care

    June 14, 2021

    The anticipation is palpable.  It’s the early 1970s and you’ve just paid a whopping $7 to hear the Who, live and in concert.  The hall is full.  The audience is cranked and ready to rock; but before Roger Daltrey can come on stage to sing Pinball Wizard and assure you that We Won’t Be Fooled Again, you must first endure the undercard.  That is, you have to sit through 30 minutes of a relatively unknown band that has been cast as the warm-up act.  On this night, the little-known troupe is a group by the name of Lynyrd Skynyrd.  Not bad for an opener.

  • Anesthesia Through the Lens of Demographics

    June 7, 2021

    The prevailing view among most anesthesia providers is that their patient populations are slowly aging. According to the Urban Institute, the number of Americans over 65 will more than double over the next 40 years.  By 2040, one in five Americans will be of Medicare age, while in 2000, it was one in eight.  For most clients, the percentage of patients covered by Medicare and Medicare HMO plans has been increasing by about one percent a year.  This growth in older Americans reflects the aging of baby boomers born between 1946 and 1964 during the early post-WWII era.  For example, today’s new enrollees were born in 1956.

  • Doubling Down: When Two Anesthesia Providers Are Required

    June 1, 2021

    In his heyday, no one was more proficient at belting out blues licks than Stevie Ray Vaughan.  The Dallas prodigy produced sheer magic with his beaten-up Stratocaster, wowing audiences and receiving adulation from the world’s other guitar greats.  His two other bandmates were no slouches either.  Calling themselves “Double Trouble,” they masterfully held down the rhythm section while Stevie delivered blistering tones with surgical precision. 

  • A Day in the Life of a Chronic Pain Physician Assistant

    May 24, 2021

    In last week’s e-alert, we discussed the various policy issues associated with the use of nurse practitioners (NPs), physician assistants (PAs) and nurse anesthetists (CRNAs) in a chronic pain practice. That discussion raised a number of practical questions about the services that these non-physician practitioners (NPPs) actually provide and the economics of using these providers in a chronic pain practice.  As a follow-up to that article, today’s alert takes a deeper dive into the numbers.  For the purpose of this discussion, we will focus solely on PAs.

  • Part of the Team: Non-Physician Services in Chronic Pain Practices

    May 17, 2021

    A veteran of the armed forces recently remarked that, in order to be an effective fighting force, a military unit needs some to operate weapons and others to peel potatoes.  Both groups are equally critical, though one may seem more glamourous in the eyes of others.  “An army marches on its stomach,” is a well-known maxim that makes the same point.  Cooks and commandos must work in unison if victory is to be assured.  The glory is ultimately shared by all.

  • The X Factor in Anesthesia Collections

    May 10, 2021

    When the Medicare program was established, a decision was made to implement a payment methodology that had been developed by Blue Shield. For each case submitted, an allowable would be determined based on the base value and the time units billed for the case. Actual payment to the provider would be reduced by two factors: an annual deductible and a patient responsibility, typically about 20 percent of the allowable. For the most part, commercial payers have adopted this methodology. While it is quite easy to calculate the allowable based on contract terms for most plans and while the patient portion is typically 20 percent, the impact of the deductible is much more difficult to predict because it is specific to each patient’s plan and coverage. It is essentially the anesthesia collections X factor.

  • MiraMed Announces MiraMed Helping Hands for India COVID-19 Relief Program

    May 7, 2021

    India is struggling to fight off a second crushing wave of COVID-19 cases.  Please join MiraMed Global Services, part of the MiraMed Family of Companies, in helping to raise money to help India amid a surging second wave of COVID-19 through donations to MiraMed Helping Hands for India COVID-19 Relief.

  • Exploring the Discount Rack: Rules for Anesthesia Charge Reductions

    May 3, 2021

    Everyone likes getting a deal.  Our eyes are drawn to ads touting the “lowest prices in town” or “half off on everything in stock” or “get two for the price of one.”  We humans are hardwired to go after a bargain.  It not only saves precious financial resources, but it gives us an internal sense of our own shrewdness.  Most businesses are all too happy to draw the customers in with such offers, but this kind of enticement must end at the doctor’s door. 

  • Can a Community-Based Residency Program Address Needs in Anesthesia?

    April 26, 2021

    The specialty of anesthesia has seen two significant responses to a perceived labor shortage. First, competition has arrived in the form of increased pressure from non-physician providers to expand their independent practice. In addition to expanding the types of providers, increased demand for physicians has yielded increasing compensation, and there has been growth in anesthesia specialization amongst medical students. Mary Dale Peterson, MD, MSHCA, FACHE, FASA, 2020 president of the American Society of Anesthesiologists (ASA), has stated, “The good news is that we’ve seen a 20 percent increase in graduates and graduate medical education positions since 2015, so we have over 1,800 anesthesiologists coming out on a yearly basis.”

  • SPECIAL ALERT: Sequestration Cuts Postponed to 2022

    April 19, 2021

    On Friday, April 16, 2021, the Centers for Medicare and Medicaid Services (CMS) announced that the two-percent sequestration cut in Medicare fee for service (FFS) payments to providers, scheduled to commence April 1, 2021, has officially been pushed back to January 1, 2022.  A recent Medicare Learning Network (MLN) article provided some background on the sequestration implementation schedule.  It stated, in pertinent part:

  • On Second Thought: Correcting the Anesthesia Record

    April 19, 2021

    In November of 1948, editors of the Chicago Daily Tribune published the results of the U.S. presidential election under a bold front-page headline that read: “Dewey Defeats Truman.”  The only problem is that, to my recollection, we have never had a President Dewey.  The newspaper was so sure that New York Governor Thomas E. Dewey would win in a walk that they prematurely published the headline before all the results were in—in part because an impending local printer’s strike forced the paper to go to print hours before they normally would have.  Oops.

  • The Impact of Covid-19 on Chronic Pain Practices

    April 12, 2021

    As the largest provider of outsourced billing and practice management services to the American anesthesia community, we tend to focus primarily on the impact of regulatory and economic changes on our anesthesia clients; but a significant percentage of our clients also provide a range of chronic pain services.  This raises the question of how these practices fared in 2020 as the pandemic was unfolding across the country.  Answering this question and understanding what distinguishes the services of anesthesiologists providing chronic pain management from those provided in the operating room and delivery suite requires a very different analytical lens.   It is easy to oversimplify the impact by suggesting that Covid caused a reduction in activity, which resulted in a drop in revenue.  Such a perspective fails to recognize the potential of chronic pain as we move into a post-Covid era.

  • Signing on the Dotted Line: The Rules for Anesthesia Record Signatures

    April 5, 2021

    The delivery man comes to the door with an expensive package.  You greet him, and he asks: “Will you sign for this?”  You’re at the closing for your first house; and, as they hand you a pen and a stack of documents, you say: “I feel like I’m signing my life away.”  There is no doubt that in the modern world we are requested or required to authenticate certain transactions by way of affixing our name to some type of paper or digital medium.  However, this is not just a modern phenomenon.  Remember John Hancock’s bold signature on the Declaration of Independence, or how about the ancient kings who would depress their signet ring into wet clay or soft wax to produce their official signature and seal?

  • Medicare Begins Recoupment of Advanced and Accelerated Payments

    April 2, 2021

    The Centers for Medicare and Medicaid Services (CMS) released a Medicare Learning Network (MLN) article on April 1 concerning the Advanced and Accelerated Payment Program (AAPP).  As our readers will recall, this was one of several programs the federal government made available to medical providers who were facing financial difficulty due to the public health emergency (PHE).  Those choosing to avail themselves of these emergency disbursements were essentially taking out a loan.  Those loans have now become due.

  • CMS to Hold Claims Pending Congressional Action on Sequester Suspension

    April 1, 2021

    As many of our readers may remember, the mandatory sequestration payment reduction of two percent, to be applied to all Medicare Fee-For-Service (FFS) claims, was put on hold by the Coronavirus Aid, Relief, and Economic Security (CARES) Act.  The suspension of these payment cuts ran from May 1 through December 31, 2020.  Then, the Consolidated Appropriations Act (CAA), signed into law on December 27, extended the suspension of sequestration through March 31, 2021.  That means that today, April 1, the two-percent cut in Medicare payments are scheduled to go into effect.  However, help may be on the way.

  • Putting Anesthesia Flat Fee Services in Perspective

    March 29, 2021

    Each year the American Society of Anesthesiologists (ASA) publishes an updated version of its Relative Value Guide (RVG).  Most updates include only minor coding changes, although every so often there are relevant policy statement updates.  The revisions contained within the 2020 RVG stand as a significant exception.  This is because a certain set of flat-fee services that had previously been assigned base unit values within earlier RVG editions were now listing only work relative value units (RVUs) for these services.  The table below includes three representative examples.