Is Your Concurrency Software Compliant?
Hal Nelson, CPC
Director of Compliance and Client Services, ABC
As part of our desire to keep both clients and readers up to date, the Communiqué has been printing compliance information since its inception. In the Compliance Corner, we will now formally keep you abreast of the various compliance issues and/or pick out a topic that would be of interest to most of our readers.
Anesthesia groups that practice in a “care team” setting use concurrency software to calculate the maximum number of cases that an anesthesiologist is medically directing at any given time. This software ultimately assigns concurrency modifiers to each claim being billed, thus influencing the expected allowable that an insurance company will pay. The biggest flaw with such concurrency programs is their inability to properly handle intra-operative handoffs, or relief.
For example, Anesthesiologist A begins medically directing a case at 2:00pm. Anesthesiologist B takes over the case at 3:00pm and the case ends at 3:30pm. Unless your concurrency software has the ability to input multiple anesthesiologists with multiple start/stop times on the same case, the software is not giving you accurate data.
From a billing standpoint, relief cases are billed under one anesthesiologist’s name with the total case time. This anesthesiologist’s name billed is typically the physician with the greatest amount of time in the case. However, from a compliance perspective, each physician’s start/stop times need to be analyzed for concurrency in order to properly select the correct medical direction or medical supervision modifier.
In the example given above, Anesthesiologist A may have a maximum concurrency ratio of three CRNA rooms from 2:00-2:59pm. Anesthesiologist B may have a maximum concurrency ratio of five rooms from 3:00-3:30. If the concurrency analysis is run only on Anesthesiologist A from 2:00-3:30pm, the concurrency modifier assigned will be incorrect, which will result in a potential overpayment from the payer, as shown in Figure 1.
In conclusion, intra-operative handoffs should be well documented on the anesthesia record and concurrency should be run on each anesthesiologist’s individual times in order to properly calculate the modifier assigned on the claim form. Since Medicare medical direction (1-4 concurrent CRNA rooms) pays 50% of the allowable to anesthesiologist, while medical supervision (5+ rooms) pays a maximum of only 4 units to the anesthesiologist, it is crucial that your concurrency reports be able to substantiate the modifier billed on each case.