Anesthesia Business Consultants

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

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Anesthesia Industry and Market News: eAlerts

eAlerts are the latest industry information regarding regulatory changes, helpful compliance reminders, or any number of relevant topics in the fast-paced, ever-evolving speciality of anesthesia.

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eAlerts

  • Successful Outcomes in Anesthesiology and Pain Medicine or Your Money Back—Really?

    January 26, 2015

    Are we heading toward a health care system in which medical care comes with a money-back guarantee?  That would seem to be the ultimate stage of accountability.  We do not see anesthesia, pain medicine or any other practices offering to refund payments if patients are not satisfied on the horizon.  We are aware of only one instance of a money-back offer in health care:  Janssen Pharmaceuticals recently entered into an arrangement with the English National Health Service under which Janssen UK will refund the cost of its hepatitis C drug Olysio for patients who do not successfully clear the virus after 12 weeks.  Janssen will also offer free access to pre-treatment blood tests to determine which patients are likely to benefit from treatment.  (McKee S.  Janssen offers NHS to pay for Olysio failures.  PharmaTimes Digital, January 15, 2015.)

  • Bundled-Payment Episode-of-Care Resources for Anesthesiologists

    January 19, 2015

    On many lists of the top five, or ten, or twenty trends to watch this year are bundled payment programs.  Bundled payments are taking hold more and more firmly.  Although traditional fee-for-service is still the dominant method of payment for anesthesia services, we should all be familiarizing ourselves with emerging payment methodologies including bundled or “episode of care” systems along with accountable care organizations and shared savings programs.

  • How Much Do Physician-Rating Web Sites Tell You about Anesthesiologists and Pain Physicians?

    January 12, 2015

    If anesthesiologists and pain specialists are like other physicians, at least as far as this question goes, online rating web sites like HealthGrades and Vitals do not provide much useful information on provider quality.

  • Impact of the Recovery Audit Contractor (RAC) Program on Anesthesiologists and Other Physicians

    January 5, 2015

    Does your practice have any Medicare appeals pending?  If you have appealed a decision within the last several years, be prepared to wait a long time for a ruling.  The backlog of provider appeals has grown so that the system is heavily overloaded, causing at least a two-year delay for appeals to be heard at the Administrative Law Judge (ALJ) level.  One of the key contributing factors is the RAC program.  The number of appeal from RAC determinations has grown exponentially since the program began in 2011.  In 2013 alone, there was a 506 percent increase in appealed RA program claims over fiscal year 2012, versus a 77 percent increase in appealed claims not related to the RA program during that same period of time.

  • Anesthesia Practices’ Year in Review

    December 29, 2014

    As we write this Alert on Christmas Day, we are thinking about the tumultuous year gone by.  So much is changing so fast that it’s hard to stop long enough to catch our breath.  Below are some of the developments through 2014 that are going to shape our future, immediate and long-term.  Inclusion of a particular change or trend does not mean that it was necessarily among the most important; nor does omission mean that a given development was less momentous.  There are far too many issues for an exhaustive list.

  • Terminating the Pain Physician- or Anesthesiologist-Patient Relationship

    December 15, 2014

    It is rare that a patient’s conduct drives his or her physician to terminate the relationship, but it does happen—not necessarily in anesthesiology care, where ongoing patient relationships are the exception, but certainly in chronic pain practices.  Such an ending is uncomfortable for all the parties involved.  There are ways, however, to make the process smoother and less fraught with risk for the practice.

  • Medicare Eliminates Patient Cost-Sharing for Anesthesia for Screening Colonoscopies

    December 8, 2014

    If you provide anesthesia for a Medicare patient undergoing a screening colonoscopy, you will be able to collect 100 percent of the allowable amount from Medicare and will not need to bill the patient for any co-payment or deductible, beginning on January 1, 2015. You must, however, identify the service as screening rather than diagnostic or therapeutic through the use of the appropriate modifier on your claim.

  • Bundled Payments: Legal Considerations for Anesthesia Practices

    December 1, 2014

    Is your anesthesia or pain medicine practice participating in any bundled payment programs?  Bundled payments are single payments to providers or health care facilities (or to a combination of both) for all services furnished during an episode of care or over a certain time period.  Distribution of the single payment among the providers often entails a gainsharing and/or pay-for-performance arrangement to incentivize cost reduction and improve quality of care.  With many bundled payment packages including orthopedic, spine or cardiovascular service lines, it is almost certain that some anesthesiologists are involved.

  • What Anesthesiologists and Pain Physicians Should Know About the Future Elimination of Global Surgical Periods

    November 24, 2014

    CMS decided to make all procedures zero-day because the Office of the Inspector General has identified a number of surgical procedures that include more visits in the global period than are being furnished in fact and on average.

  • Final Rule: Public Reporting on Anesthesiologists and Other Physicians

    November 17, 2014

    The last two issues of the Alert reviewed changes to the Physician Quality Reporting System (PQRS) and to the Value-Based Payment Modifier (VM) announced in the Final Fee Schedule Rule for 2015.  This week we will note for the record some of the most meaningful numbers in the Final Rule—the conversion factors—and explore developments regarding two of CMS’ transparency ventures, the Physician Compare website and the Open Payments program.

  • The PQRS Antibiotics Measure is Gone, and Other PQRS Changes of Interest to Anesthesiologists in the Final Rule

    November 10, 2014

    CMS released the Final Rule on the Physician Fee Schedule containing next year’s Physician Quality Reporting System (PQRS) requirements on October 31, 2014.  As expected, Measure #30, Timing of Antibiotic Prophylaxis-Administering Physician, has been deleted from the list of measures available for either claims-based or registry reporting.  So has the Back Pain Measures Group (Measures #148-151) and Measure #142, Assessment for Use of Anti-Inflammatory or Analgesic Over-the-Counter (OTC) Medications, but CMS did not ultimately remove Measure #109, Osteoarthritis:  Function and Pain Assessment, from the list.

  • What Anesthesiologists Need to Know about the Value-Based Payment Modifier

    November 3, 2014

    The Final Fee Schedule Rule for 2015 applies the 2017 Value Based Payment Modifier to all anesthesiologists, CRNAs and AAs, regardless of group size, and increases the amount of payment at risk for groups with 10 or more eligible professionals) to 4 percent.

  • Preparing Your Anesthesia Practice for PQRS Reporting in 2015

    October 27, 2014

    Numerous anesthesiologists have expressed confusion about the requirements for reporting Physician Quality Reporting System (PQRS) measures next year. It is very important that every eligible professional (EP) successfully participate in the PQRS program in 2015; failure to do so will mean a two-percent reduction in their Medicare payments in 2017.

  • Getting Paid for All Your Anesthesia Time

    October 20, 2014

    Anesthesia time “starts when the anesthesia practitioner begins to prepare the patient for anesthesia services in the operating room or an equivalent area,” according to the Medicare regulations and the ASA Relative Value Guide®, or “begins to prepare the patient for the induction of anesthesia” as stated in the CPT® Anesthesia Guidelines.  What do those words mean—and can there be any remaining controversies after all these years?

  • Restrictions on Billing Anesthesia Patients Who Go Out of Network

    October 13, 2014

    Anesthesiologists are wondering how to respond to questions about an article that appeared in the New York Times on September 20, 2014, reporting on a $117,000 bill received by a spinal fusion patient from a neurosurgeon who had assisted in his procedure.

  • Anesthesiologists Need to Understand Hospital Readmission Penalties

    October 6, 2014

    On October 1, 2014, the start of the fiscal year for hospitals, Medicare’s maximum penalties for “preventable” readmissions increased from two percent to three percent. At the same time, CMS added three new conditions, including two frequently performed orthopedic procedures, to the list of conditions for which readmissions are deemed preventable, which now consists of the following:

  • Can A Computer Replace Your Anesthesiologist?

    September 29, 2014

    An article in the September 21 New York Times Sunday Review asked the question Can a Computer Replace Your Doctor? The author, Elisabeth Rosenthal (who identified herself as a “former physician”) opened with the following:

  • Anesthesiologists Ask: How Are ACOs Doing?

    September 22, 2014

    It is unusual to open a health policy periodical without seeing the words “Accountable Care Organization,” or, more frequently, “ACO.”  Are these entities as successful as they are visible?

  • New “Distinct Procedural Service” (-59) Modifiers on the Way–Anesthesia and Pain Management Practices Take Note

    September 15, 2014

    Many medical services and procedures can be performed either on their own or in conjunction with another service or procedure.  The National Correct Coding Initiative (CCI) identifies pairs of services that a physician cannot normally report for the same patient on the same date of service.  The two services may be mutually exclusive, as when one is performed only on female patients and the other only on males.  Most commonly, the reason for the linkage—the CCI “edit” that bundles the two services and prevents separate payment—is that the second service in the pair is a component of the more extensive service performed by the same physician for the same patient at the same encounter.  An example familiar to anesthesiologists is the bundling of postoperative pain management procedures with an anesthetic delivered through the same catheter.

  • Are Anesthesia Group-Hospital Gainsharing Agreements Legal?

    September 9, 2014

    "Properly structured, arrangements that compensate physicians for achieving hospital cost savings can serve legitimate business and medical purposes. Specifically, properly structured arrangements may increase efficiency and reduce waste, thereby potentially increasing a hospital’s profitability."  (Office of the Inspector General, Advisory Opinion No. 07-22, December 28, 2007.)

  • Should Anesthesia Practices Be Concerned about Phase 2 of the Government HIPAA Audit Program?

    September 2, 2014

    HHS’ Office for Civil Rights (OCR) is about to begin a new round of audits to determine the extent of providers’ and their business associates’ compliance with the HIPAA privacy, security and breach notification rules.