Anesthesia Business Consultants

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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  • ABC's Affiliate Company, Plexus Technology Group’s Anesthesia Touch Becomes First Mobile AIMS Solution to Achieve Full KLAS Rating

    August 9, 2016

    The Anesthesia Business Consultants (ABC) affiliate company and trusted Anesthesia Information Management Systems (AIMS) partner, Plexus Technology Group, LLC (Plexus TG), is pleased to announce Anesthesia Touch™ is now a fully-rated AIMS solution as scored by providers and recorded by KLAS research with a score of 891.1

  • Anesthesia Practices: Check Your Compliance with the Section 1557 Final Rule

    August 8, 2016

    An anesthesiology group decides not to provide labor epidural anesthesia to women with limited English proficiency (LEP).1

  • What Anesthesia Providers Should Know About the Opioid Crisis

    August 1, 2016

    The death in April of the musician Prince from an accidental overdose of fentanyl is only one of the more highly publicized instances of a public health problem in the United States that has reached epidemic scale. According to the Department of Health and Human Services (HHS), 44 people die every day in the U.S. from an overdose of prescription painkillers.

  • VA’s Proposed Rule to Expand Nurses’ Practice Could Impact Anesthesia Specialty

    July 25, 2016

    Few are unfamiliar with the general state of veterans and healthcare in our country. According to statistics recently released by the VA, an average of 20 veterans died from suicide in 2014.1 Further, there is a backlog of nearly 500,000 veterans waiting 30 days or longer to receive care at VA facilities across the U.S. This is higher than the numbers from one year ago when reports were released that showed veterans dying while waiting for care as a result of the backlog.2 In an effort to combat these problems—seen, in part, as a result of a shortage of physicians—the VA issued a Proposed Rule, Advanced Practice Registered Nurses (APRN), aimed at allowing APRNs to practice within their full authority (Proposed Rule).

  • CMS Becomes Arch Nemesis of Hospitals with Plans for Site-Neutral Rates in Outpatient Payment Rule

    July 18, 2016

    To hospitals, the Centers for Medicaid & Medicare Services (CMS) is acting like the terrible Wicked Witch of the West from the movie the Wizard of Oz because of their proposed plans for site-neutral rate reductions. The proposed modifications in reimbursement are included in the 2017 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System (CMS-1656-P) proposal submitted on July 6, 2016. The law provides for payment system policy changes, quality reporting provisions, and reduced pay rates that many hospitals would prefer to douse with water and have them disappear like the Wicked Witch rather than have payments reduced at their off-campus facilities.

  • Negotiating Anesthesia Contracts Like a Pro

    July 11, 2016

    Prior to addressing the main topic of today’s alert, we felt it necessary to inform our readership of the recent proposed changes made by the Centers for Medicare and Medicaid Services (CMS) in its CY 2017 Proposed Physician Fee Schedule (PPFS). In the CY 2016 PPFS, CMS proposed reexamining the anesthesia codes reported in conjunction with colonoscopy procedures (i.e., 00740 and 00810) as potentially misvalued. In the CY 2017 PPFS, CMS continues to maintain that 00740 and 00810 are misvalued and it “look[s] forward to receiving input from interested parties and specialty societies for consideration during future notice and comment rulemaking.” Moreover, CMS notes that although sedation services are included in certain endoscopic procedures, that anesthesia is being separately reported. As such, “[i]n the CY 2017 PFS proposed rule, CMS is proposing values for the new CPT moderate sedation codes and proposing a uniform methodology for valuation of the procedural codes that currently include moderate sedation as an inherent part of the procedure. CMS is also proposing to augment the new moderate sedation CPT codes with an endoscopy-specific moderate sedation code, and proposing valuations reflecting the differences in physician survey data between gastroenterology and other specialties.”1 As always, we encourage our readers submit comments to CMS or to reach to their professional associations and encourage them to submit comments. CMS will accept comments until September 6, 2016.

  • ICD-10: Are You on Track?

    July 5, 2016

    The transition to the International Classification of Diseases and Related Health Problems 10th revision (ICD-10) appears to have gone well so far, despite widespread anxiety that it would wreak havoc across healthcare as providers struggled to comply with the new coding structure, heightened specificity and documentation requirements.  The Centers for Medicare and Medicaid Services (CMS) reports that total claims denials and other claims metrics remained essentially unchanged from the historical baseline to the fourth quarter of calendar year 2015.

  • What Anesthesia Professionals Need to Know About Medicare Revalidation

    June 27, 2016

    All physicians, group practices and other providers who participate in Medicare are required to resubmit and recertify the accuracy of their enrollment information every five years through a revalidation process.

  • Anesthesia Professionals and Alarm Fatigue

    June 20, 2016

    The ASA adopted its Statement on Principles for Alarm Management for Anesthesia Professionals at its annual meeting in October 2013.  The introduction to the Statement provides as follows:

  • Federal Court of Appeals Slaps CMS’s Wrist: What Anesthesiologists Should Know

    June 13, 2016

    Have you ever found that you could not make heads or tails of a Medicare regulation? Have you wondered whether even CMS could decipher and coherently apply its own rules? The sheer volume of regulations makes it difficult to be certain of one’s interpretation:

  • When May Anesthesiologists Offer Professional Courtesy, Co-Payment and Cash Payment Discounts?

    June 6, 2016

    Most anesthesiologists know in general fashion that there are "compliance" issues with professional courtesy, co-payment waivers and discounts for cash payments.  Yet confusion persists about exactly how to handle these situations.

  • Growing Limits on “Surprise Bills” from Anesthesiologists and Others

    May 31, 2016

    For patients who undergo a surgical procedure, the anesthesiologist’s bill sometimes comes as a surprise.  If the hospital and the surgeon are participating in the patient’s health plan but the anesthesiologist is not in the network and bills the difference between his or her full charge and what the health plan paid, the amount that the patient owes can be a nasty shock.  Large balance bills are often stressful for patients and are a major source of medical debt.

  • Anesthesia Practices Should Think About Price Transparency

    May 23, 2016

    “Transparency” is a word that you will encounter more and more frequently in health policy articles, including ABC’s publications.  Information transparency is a key for enabling healthcare purchasers to make value-based decisions concerning the quality and price of services.  Those data are slowly becoming more available, but they remain largely inaccessible to most potential users.

  • Checklists – As Important As Ever in Anesthesia Patient Safety

    May 16, 2016

    “Patient Safety Issues Spur NIH Shake-Up” was an above-the-fold headline in the Washington Post on May 11, 2016.  NIH Director Francis Collins, MD is replacing top leadership at the 200-bed Clinical Center with a new management team with experience in oversight, compliance and patient safety in the wake of an independent review that found that safety had become “subservient to research demands.”

  • How the MACRA Regulations as Proposed Will Affect Anesthesiologists, Part II (Alternative Payment Models)

    May 9, 2016

    Last week’s e-Alert introduced our readers to the proposed regulations implementing the MACRA Quality Payment Program (Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models).  We focused in Part I on the MIPS pathway, which consolidates Medicare’s current quality, cost and EHR reporting programs and promised an overview of the second major physician payment pathway set forth in the proposed rule, the APM Incentive program.

  • How the MACRA Regulations as Proposed Will Affect Anesthesiologists, Part I

    May 2, 2016

    CMS released the proposed regulations implementing MACRA on April 27, 2016.  New quality-based payment systems will replace and streamline the PQRS, the value modifier and the meaningful use programs.  Physicians will have the opportunity to earn up to a four percent bonus in 2019 based on their participation in the Merit-Based Incentive Payment System (MIPS) or a five percent bonus for participating in a qualifying Alternative Payment Model.

  • A Proposed Update to CMS’s Two-Midnight Rule

    April 25, 2016

    On July 13, 2015, we informed you of CMS’s Two-Midnight Rule.  After much pushback from industry stakeholders and from the judicial system since our alert, CMS proposes to eliminate the notorious payment reduction under the Two-Midnight Rule in its FY 2017 Medicare Inpatient Prospective Payment System (IPPS) Proposed Rule (Proposed Rule).  Though not slated to be finalized until the latter part of 2016, hospitals and their partners can be optimistic that the penalty under the Two-Midnight Rule may soon be a memory. 

  • Colonoscopies Allegedly Safer Without Anesthesia Services—Really?

    April 18, 2016

    A new study appearing in Gastroenterology contends that the overall risk of complications after colonoscopy increases when individuals receive anesthesia services. This study should not lead to any restrictive payment changes. Its analysis is flawed and the actual difference between the West, to which is attributed the highest risk, and the Northeast (lowest) is a clinically-insignificant 1.5 percent, as shown here.

  • Anesthesiologists, Do You Know Where Your Ultrasound Images Are?

    April 11, 2016

    Many pain medicine procedures, and, increasingly, perioperative and critical care procedures such as central venous access are performed using ultrasound guidance (U/S).  Indeed, U/S is an integral part of many CPT® codes, e.g., 20604 [Arthrocentesis, aspiration and/or injection, small joint or bursa, (e.g., fingers, toes), with ultrasound guidance, with permanent recording and reporting].  When and where, and by whom, must those permanent images be stored?  What if another entity, such as a hospital, is responsible for storing them?  According to Sonosite,

  • Anesthesia Practices May Be Subject to the Phase 2 HIPAA Audits

    April 4, 2016

    If you receive a letter by email that begins like this:

  • Dos and Don’ts of Amending the Anesthesia Record

    March 28, 2016

    The anesthesia record, like medical records in general, should be complete and accurate at the time when the physician signs it—ideally.  In practice, it occasionally requires amendment. Given the huge role that accurate documentation plays in our medical payment system, compliance with the rules and regulations governing medical record amendments is important.  Altered medical records have great potential for fraud, especially if the added information helps to raise the level of a billable service, and no one should be surprised if auditors look at any changes closely.