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Proposed “Medical Necessity” Restrictions on Post-Anesthesia Pain Blocks

One of the Medicare Administrative Contractors (MACs), Noridian Administrative Services LLC, has published a proposed policy that would bar payment for peripheral nerve blocks placed pre-operatively for the management of post-operative pain.  According to the draft policy, entitled Nerve Blockade: Somatic, Selective Nerve Root, and Epidural,Reimbursement for the control or management of pain in the immediate postoperative period is bundled into the payment for the procedure, surgical or anesthetic—regardless of the method by which the care provider, including the anesthesiologist, decides to manage pain. Following discharge from the post-anesthesia care unit (PACU), the medically reasonable and necessary placement of regional or peripheral pain blocks or initiation of other new pain interventions or “top-up” dosing may be reimbursable. Providers should not expect separate payment for the establishment of epidural or other pain blocks unless the block is placed following discharge from PACU due to documented inadequate pain control.The last sentence of the...
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