Anesthesiologists, nurse anesthetists and anesthesiologist assistants who last validated their enrollment in Medicare prior to March 25, 2011 are going to have to revalidate again by March 23, 2013. The revalidation is required under Section 6028 of the Affordable Care Act.  According to this statutory provision, all providers and suppliers who were initially enrolled before March 25, 2011 and have not revalidated since then must revalidate their enrollment information within 60 days of receiving notice from their carriers, but no later than March 23, 2013.This is a hassle for physicians and allied health professionals who enrolled or revalidated as Medicare providers in 2009, 2010 or up until March 22nd of this year.  Normally, providers have five years to revalidate.   It may be of modest consolation that the burden will be considerably greater for institutional providers and especially for suppliers.  That is because the revalidation is intended to combat Medicare fraud, by bringing...

CMS has proposed to begin paying certified registered nurse anesthetists (CRNAs) for providing certain pain management procedures on a nationwide basis.  The discussion in the proposed rule on the Medicare Physician Fee Schedule for calendar year 2013, issued on July 6, 2012, sets forth the history and the considerations in expanding the types of services for which CRNAs may bill Medicare.Currently, whether pain services may be reported by CRNAs varies from state to state.  There are two circumstances that must be present for Medicare to pay for CRNA pain services:CRNAs must be permitted to perform pain medicine procedures under state scope of practice laws, andThe Medicare contractor for the state must have determined that chronic pain management is closely related to anesthesia and that CRNA-performed pain procedures are therefore covered by the Medicare program.It is important to understand that Medicare pays for specific benefits, not for all medical, nursing and other health services. ...

The Supreme Court’s decision on the fate of the Patient Protection and Affordable Care Act (PPACA or, more commonly, ACA) is due to be announced at 10:15 on Thursday morning, June 28.  We are not jumping the gun by beginning to write this Alert ahead of the decision – the take-away message is that whether the ACA stands or falls, in whole or in part, anesthesiologists need to continue developing their role in perioperative care.Towards the Perioperative Surgical Home™ Model of CareCoordinated medical care is now an established value and goal in both the public and private sectors.  “Silos” and “fragmentation” are pejorative terms used to describe the type of health care delivery system that policymakers seek to leave behind. Many anesthesiologists began expanding their role in coordinating perioperative care long before the ACA was written, in pre-anesthesia testing through post-operative pain medicine services.  Several years ago, the American Society of Anesthesiologists...

A product of 1989 legislation, the Physician Fee Schedule went into effect on January 1, 1992.  (And William Hsiao, PhD, whose study of Resource-Based Relative Value Systems was the foundation for the change from charge-based payment methodology, is still teaching at the Harvard School of Public Health today.)The national anesthesia conversion factor (CF), unadjusted for geographic practice cost differences, was $13.68 in 1992, and the general CF for other services was $31.00.  Twenty years later, the national anesthesia CF is $21.49, and the general CF is $34.04 – at least for the period ending on February 29, 2012.  In mid-December, Congress passed the “Middle Class Tax Relief and Job Creation Act,” setting a zero percent update and postponing the scheduled 27.4 percent CF reduction mandated by the Sustainable Growth Rate (SGR) for just two months.  If Congress cannot agree on a longer-term deal averting the SGR cuts, Medicare payments will drop...

Further Clarification of eRx Penalty and Hardship ExemptionThe Medicare eRx Incentive Program is turning out to be the Full Employment for Healthcare Writers program.  Last week we described how anesthesiologists, pain physicians and nurse anesthetists with prescribing privileges could apply for a hardship exemption using a new CMS web page, the Communication Support Page.   “Most anesthesiologists … will not qualify for either the eRx bonus or the eRx penalty because they submit very few electronic prescriptions and report very few of the outpatient visits encompassed by the eRx measure.”We would like to reemphasize this point.  Anesthesiologists are not subject to any eRx penalty this year if they did not:Submit claims to Medicare for at least 100 outpatient or office visits, for dates of service between January 1, 2011 and June 30, 2011.  Only those evaluation and management services identified by one of the CPT™ codes in the measure specification (including codes 99201,...