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

  • 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.

  • The Two-Midnight Rule and the Anesthesia Department

    August 25, 2014

    The “two-midnight rule” was established by the 2014 Medicare inpatient prospective payment rule. According to the policy, inpatient admissions extending through at least two midnights generally qualify for Medicare Part A payments. Surgical procedures, diagnostic tests and other services are presumptively appropriate for inpatient hospital admission and payment when (1) the physician “reasonably” expects the patient to require a stay that crosses at least two midnights and (2) admits the patient to the hospital based upon that expectation. Inpatient stays lasting fewer than two midnights are considered and should be billed as outpatient or observation services under Medicare Part B.

  • Physician Payments Sunshine Act: Anesthesiologists Should Register and Review Their Information

    August 18, 2014

    One of our readers asked us recently what his group needed to report under the Physician Payments Sunshine Act.  The answer:  nothing.  The Sunshine Act, which is part of the Affordable Care Act, requires pharmaceutical and medical device manufacturers to report payments and other items of value worth more than $10, as well as certain ownership interests held by physicians and immediate family members.  (See our Alert of August 5, 2013, Drug Manufacturers’ Payments to Anesthesiologists Are Now Reportable under the Sunshine Act.)  It does not impose any tasks on physicians.

  • What the Surgeon Wants from the Anesthesiologist and Nurse Anesthetist

    August 11, 2014

    We recently had the opportunity to talk with one of our favorite surgeons about what she wants from her anesthesiologist or care team.  Some of the items on the list below will be very familiar—so much so that it’s surprising that the issue still comes up.  Others are specific to our surgeon’s specialty, otolaryngology, they may sensitize readers to analogous concerns affecting other specialties.

  • Some Financial and Strategic Challenges Facing ASCs: What Anesthesiologists Should Understand

    August 4, 2014

    Ambulatory or outpatient anesthesia accounts for approximately 60 percent of surgeries in the U.S. today.  The majority of anesthesia practices provide services at one or more of the 5,300 Medicare-certified ambulatory surgical centers (ASCs).  The challenges faced by ASCs—whether hospital-owned or independent—affect us all.  In order to be your ASCs’ valued partners, anesthesiologists and nurse anesthetists need to understand how healthcare’s challenges in general and ASC’s challenges in particular affect your facilities.

  • Latest Obamacare Litigation—A Summary for Anesthesiologists

    July 28, 2014

    Some of the most controversial provisions of the Affordable Care Act (ACA) are those that require individuals to either sign up for health insurance or to pay a tax.  Differing interpretations of the statutory language regarding the tax credit or “subsidy” that would enable lower-income individuals to afford coverage have given opponents of ACA a hook on which to hang a small but powerful legal weapon.  Contrary to the claims (and hopes) of some observers, recent federal Appeals Courts decisions are not the death knell for Obamacare, however.