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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eAlerts
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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).
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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.
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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.
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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.
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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.
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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:
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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:
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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.
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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.
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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.
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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.”
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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.
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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.
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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.
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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.
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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,
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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:
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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.
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Concurrent Cases Can Be a Problem Not Just for Anesthesiologists
March 21, 2016
Recent media coverage of surgeons operating in two concurrent cases raises three issues: (1) patient safety, (2) compliance with the Medicare teaching physician billing rules and (3) transparency vis-à-vis patients.
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The Burden of Measuring Quality in Anesthesiology and Other Physician Practices
March 14, 2016
Donald Berwick, MD, senior fellow at the Institute for Healthcare Improvement (IHI) (and a former CMS administrator) described nine steps to advance healthcare into “the moral era” at an IHI forum in December, 2015. One of those steps was to “stop excessive measurement.” Dr. Berwick said:
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New Guidelines for Managing Postoperative Pain: Anesthesiologists Take Note
March 7, 2016
The American Pain Society last month released a set of Clinical Practice Guidelines on the Management of Postoperative Pain. The key recommendation in the Guidelines is for greater use of multimodal pain management strategies.
