Anesthesia Business Consultants

Weekly eAlerts Covering Regulatory Changes, Compliance Reminders &
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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 specialty of anesthesia.

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July 10, 2017


CMS has sent approximately 8,000 anesthesia practitioners a CBR on anesthesia for lower endoscopy. These data-driven reports show clinicians how their billing patterns compare with those of their peers at the state and national levels. We request that our clients send ABC a copy of this CBR or any other CBR that they receive so that we can review it, assist in understanding what it means and, if necessary, provide additional training and resources.

They might seem innocuous and inconsequential in your anesthesia practice’s vast sea of paperwork and electronic data, but comparative billing reports (CBRs), administered by the Centers for Medicare and Medicaid Services (CMS) and prepared by a data mining company called eGlobalTech (eGT), are not something to ignore.  Anesthesia groups need to know what CBRs are and educate billing and other office staff about the importance of referring these reports to group leadership and the appropriate clinicians in a timely fashion.

Don’t de-prioritize CBRs; they merit a prompt review.  The reports could potentially make your group eligible for a CMS audit farther down the road, but they also offer an opportunity for individual clinicians and the practice as a whole to identify possible areas for additional training and improvement.

As explained in recent communications from ABC account managers to our clients, CBRs are educational tools that show an individual practitioner how their billing pattern on a given procedure(s) compares with that of their peers at the state and national levels.  The reports serve CMS as a strategy to ensure coding accuracy.

CBRs provide data-driven tables and graphs and an explanation of the findings, indicating whether the clinician’s average is statistically significantly higher or simply higher than the state and national averages; does not exceed the averages; or is based on insufficient data because the clinician has not performed the procedure a sufficient number of times for statistical comparison.  The graphic presentations are designed to help clarify the clinician’s billing patterns. (Please note that CBRs provide a statistical analysis only and do not offer any other type of outside review or evaluation.)

Medicare Administrator Contractors (MACs) have been distributing CBRs on a limited basis for several years, but CMS has recently formalized and expanded the program nationally.  The agency selects areas for data analysis by eGT that are prone to improper payments based on reports by the Health and Human Services Office of the Inspector General (OIG) or Government Accounting Office (GAO) and other sources that have identified potential payment vulnerabilities.  eGT has distributed five CBRs so far in 2017.

CBRs in Anesthesia

At CMS’s direction, eGT prepared and issued a CBR in June on anesthesia for lower endoscopic procedures focusing on CPT® Code 00810 and including Medicare services for colonoscopies submitted with CPT Codes 45300-45398, G0105, and G0121.  The CBR covers three metrics:

  • Average time units per visit
  • Percentage of visits billed without an allowed endoscopy claim by an endoscopist
  • Percentage of visits appended with modifier AA (anesthesia personally performed by physician). (Of course, this metric is strongly dependent on practice type and other factors.)

An educational webinar will be held on this topic by eGT and partner Palmetto GBA on Wednesday, July 12, 3-4 pm EST.  ABC plans to attend the webinar, and we encourage our clients to do the same; however, audio and audio-video recordings will be available through eGT for those who are unable to attend.

We request that our clients send ABC a copy of this CBR or any other CBR that they receive so that we can review it, assist in understanding what it means and, if necessary, provide additional training and resources.

According to CMS, the CBR issued in June, sent to approximately 8,000 anesthesia providers, was prompted by increased Medicare spending on anesthesia for lower endoscopic procedures.  The Medicare Fee-for-Service 2015 Improper Payments Report identified anesthesia as one of the top 20 service types with the highest improper payment rates.  Also prompting the CBR was the increase in screening colonoscopies that accompanied coverage of this procedure under the Affordable Care Act (ACA).  The expectation is that other anesthesia-related CBRs will also be issued in the future, so your group should be aware that they could be coming.

Reviews Recommended

Though intended to educate clinicians about their billing patterns and ensure proper coding, a CBR indicates that an individual anesthesia provider is an outlier in a given procedure, and that outlier status is definitely something your group and the individual clinician(s) should validate and understand.

For this reason, we strongly recommend conducting an internal management-led review to ensure that the group is protected in case it comes up against additional scrutiny for issues related to being an outlier in these reports.

In our view, CBRs should not be viewed as only educational; rather, we believe the most prudent approach is to check your data to assess the validity of the outlier status, and determine whether you are comfortable with that outlier status based on your service levels and documentation, or if you might need to adjust your practice parameters.  Repeated inclusion in an outlier category could prompt an audit of the pertinent cases.  There may be valid reasons for the outlier status, such as practice patterns;  regardless, it’s important to know the basis for your inclusion and if any corrective measures should be taken.

Extensive resources related to the CBR on anesthesia for lower endoscopy, including a sample CBR, a statistical debriefing, recommended links and frequently asked questions are available here

ABC clients:  If you have any questions about CBRs in general or the recent CBR related to lower endoscopies, please contact your account manager.

With best wishes,

Tony Mira
President and CEO