The Anesthesia Quality Institute was founded to create and maintain the National Anesthesia Clinical Outcomes Registry (NACOR). This project is now two and a half years old and more than 135 practices, including nine ABC clients, have contributed more than 5 million records to this “every case, every day” registry. Participants have online access to the NACOR Reporting Server, where they can see continually updated summaries of their practice performance and aggregated national benchmarks. This information, and the ability to slice and dice it to examine subsets of interest, is an important business and quality management tool. After all, what can’t be measured can’t be improved.
Or can it? Although we pride ourselves on our data-driven, scientific, high-tech practice, anesthesiology remains as much art as science. As the popularity of morbidity and mortality conferences attests, there is a lot to be learned from the unfortunate experience of others. Schadenfreude aside,...
Patients who go out of network can present serious collections problems for the physicians who do not participate in the network. Managed care organizations (MCOs) often send the check to the patient in order to pressure physicians to sign participation agreements, leading to the necessity for practices to collect directly from the patients, something that is especially challenging for hospital-based anesthesiologists and other physicians who do not have ongoing relationships with their patients.MCOs do not like patients going out of network either, and increasingly some payers are going to extreme lengths to discourage that behavior. The efforts of one such payer, Aetna Health of California, Inc., to limit the use of out of network services recently led to the filing of a lawsuit. On July 3, 2012, the California Medical Association (CMA), three county medical societies, and a coalition of four surgery centers and 60 physicians and one unidentified patient brought an...
Many, if not most, anesthesia practices provide services at ambulatory surgical centers (ASCs) as well as at hospitals. Some 11 percent of anesthesiologists have invested in the ASC as part owners, according to Medscape’sAnesthesiology Compensation Report: 2011 Results. Others invest their energy in contracts to staff ASCs. In either case, it is important to know the economic condition and value of one’s ASC.One way to approach the matter is to analyze the attractiveness of the ASC to a buyer. Buyers tend to invest in outpatient facilities with room for improvement in performance. Whether you are considering buying (or selling) an ownership share or entering into or renewing an exclusive contract, the ASC’s appeal to a potential corporate investor such as an ASC management company is relevant.Becker’s ASC Review E-Weekly ran an article with “10 Questions to Evaluate ASC Investment Opportunities” in its June 16, 2012 issue. Outpatient Surgery Magazine alerted subscribers to a 2009...
This issue of the Communiqué is a keeper. On pages 6 through 10 you will find tables that lay out clearly the Electronic Health Records (EHR) incentive program’s Stage 1 Meaningful Use objectives, the recently proposed changes to Stage 1, and the potential Stage 2 objectives, measures and exclusions as proposed by CMS in March. The objectives, translated into measures, are capabilities that your EHR must have in order for you to qualify for the incentive, which is non-negligible at a maximum of $44,000 per physician, or to avoid the penalty for non-compliance. Even though the proposed changes discussed in the Meaningful Use article by Abby Pendleton, Esq. and Stephanie Ottenweis, Esq. are likely to be different in some respects when CMS issues the final regulation later in the year, it is worth familiarizing yourself with the proposals because understanding the final versions will be that much easier.The Meaningful Use article,...
Anesthesiologists and pain physicians who have been receiving bonuses for participating in Medicare’s Physician Quality Reporting System (PQRS) should continue to do what they have been doing. The proposed Fee Schedule rule (NPRM) for 2013 does not contain any new requirements affecting those who are already successfully participating, as we noted summarily in last week’s Alert.For physicians who have yet to earn a PQRS incentive payment, the NPRM would make reporting easier in future years. This is important, because failure to report PQRS measures will result in financial penalties beginning in 2015—based on reporting in 2013. The amount of the payment adjustment, positive or negative, will be as follows: 2013+0.5% 2014+0.5% 2015-1.5% 2016 on-2.0% CMS has stated that one of its major goals in developing its proposed changes was to increase participation to 50% of eligible providers in 2015. In 2010, the overall level of participation was only 24 percent. (“2010 Reporting Experience, Including Trends (2007-2011): Physician...
A change to some language in the Anesthesia Services chapter of the Medicare National Correct Coding Initiative (NCCI) manual recently created considerable confusion among participants in the on-line discussion maintained by the Medical Group Management Association (MGMA) for the Anesthesia Administration Assembly (AAA).The information that gave rise to the confusion has been clarified. The NCCI has confirmed that there has been no policy change here; epidurals and blocks placed preoperatively for the management of postoperative pain are still separately reportable and not bundled into the anesthesia service unless they are used as the method of administering the anesthesia itself. Because the issue of post-op pain management is a perennial hot topic, we take this opportunity to help ensure that no incorrect interpretations take root.Chapter II of the NCCI manual, “Anesthesia Services,” was revised effective January 1, 2012. It contains a number of statements that are consistent with the established principles of billing...
The most significant change for anesthesia and pain medicine practices in the proposed Medicare Fee Schedule rule for 2013 (NPRM), released on July 6, 2012, was the proposal to allow nurse anesthetists to perform chronic pain services without physician supervision in those states that include such services in the scope of practice of nurse anesthesia. As noted in last week’s Alert, the 765-page NPRM contains many other potential changes. Highlights appear below.1. Medicare Payment Rates in 2013It comes as no surprise that the 27 percent cut mandated by the Sustainable Growth Rate (SGR) formula remains in place for now and will take effect on January 1, 2013, if Congress fails to act. Fear of the economic cliff that the entire country faces with mandatory spending reductions and the expiration of tax cuts early next year will undoubtedly affect how Congress deals with the SGR for 2013; what we cannot predict now...
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. ...
Do you check your professional association’s web site regularly? There is more practice-related information there than you may realize. One recent addition to the resources on the American Society of Anesthesiologists web site (www.asahq.org) is worth your special attention. The ASA Committee on Quality Management and Departmental Administration (QMDA) has produced a comprehensive set of questions for anesthesiologists and others involved in perioperative patient care that can guide the development of a quality program tailored to your own department.The QMDA Anesthesiology Department Quality Checklist is a “compendium of anesthesia safety and quality measures suitable as a reference for anesthesiology departments of any size as they develop a comprehensive set of quality standards.” It consists of separate sets of questions for these individuals and offices:Chair of AnesthesiaStaff AnesthesiologistSurgeonCRNA and/or AA Perioperative Nursing ManagerOperating Room NursePACU Nursing ManagerObstetric Nursing ManagerQuality ManagementAdministrationAnesthesia Technicianas well as for Office Based Anesthesia Facilities. The questions, and the answers received, can...
State governments are under severe financial pressure. In the last few years, many of them have stepped up their efforts to collect unclaimed property held by private entities such as medical practices. Every state has an “escheat” or unclaimed property statute that places the burden on those holding such property to deliver it to the treasury or commerce department if the owner cannot be found. Escheatment is the general rule that abandoned or unclaimed property (of all kinds) becomes the property of the state.Several questions about our clients’ escheat policies and procedures have come up recently, suggesting that it is time for all to review their compliance with the applicable laws. This subject is governed by state statutes that vary in their requirements regarding attempts to notify the owner of the property, e.g., the patient; time limits for delivering the property to the authorities, and other financial procedures. Forty-two states (including...
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,...
Medicare’s Value-Based Purchasing (VBP) program for hospitals, mandated by the Affordable Care Act, took off upon the release of final regulations on April 29, 2011. VBP marks the start of true pay-for-performance, as opposed to pay-for-reporting, at the hospital level. The intent is to pay for better value, patient outcomes and innovations, and not simply to reward volume of services. As we enter 2012, we are halfway through the first performance period. Anesthesiologists should begin analyzing and planning how they might partner with their hospitals in achieving the scores necessary to earn VBP incentives.The hospital scores are based on Clinical Process of Care measures (70%) and on Patient Experience of Care (30%) as measured by completed Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) surveys. Hospitals receive points for achievement and improvement for each measure in the two domains, with the greater set of points counting toward the domain total....
Another Medicare compliance deadline approaches, and it has attracted a fair amount of attention. The good news is that it will apply to few pain physicians and even fewer anesthesiologists. Sometimes it is necessary to explain a new rule or requirement just so that our readers know not to worry. This is one of those times.By July 1, 2012, those physicians and facilities that are affected are expected to be in compliance with the “3-day payment policy.” The 3-day payment window applies to certain outpatient services provided by hospitals and hospitals’ wholly owned or wholly operated entities, including physician practices.The policy has applied to diagnostic services and related non-diagnostic services since 1998. The Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 broadened the definition of related non-diagnostic services that are subject to the payment window to include any non-diagnostic service that is clinically related to...
A change to some language in the Anesthesia Services chapter of the Medicare National Correct Coding Initiative (NCCI) manual recently created considerable confusion among participants in the on-line discussion maintained by the Medical Group Management Association (MGMA) for the Anesthesia Administration Assembly (AAA).The information that gave rise to the confusion has been clarified. The NCCI has confirmed that there has been no policy change here; epidurals and blocks placed preoperatively for the management of postoperative pain are still separately reportable and not bundled into the anesthesia service unless they are used as the method of administering the anesthesia itself. Because the issue of post-op pain management is a perennial hot topic, we take this opportunity to help ensure that no incorrect interpretations take root.Chapter II of the NCCI manual, “Anesthesia Services,” was revised effective January 1, 2012. It contains a number of statements that are consistent with the established principles of billing...
Anesthesia Business Consultants' (ABC) dedication to the complex and intricate specialty of anesthesia and pain management requires continued commitment to technology and collaboration with the technology leaders in the industry. ABC and Picis are pleased to announce a strategic partnership to leverage the combined strengths of technology and operations to all facets of the anesthesia community.
Anesthesiologists, along with the hospitals and ASCs they serve, continually evaluate their technology partners and how to best utilize the value they contain. By the joint efforts of ABC and Picis, we enable our mutual customers with a streamlined process for billing and bring the confidence of a combined effort to the ever-increasing pressures extended by payers, patients, and regulatory bodies.
The Best Partnerships Strengthen Business Processes
As the nation’s largest billing and practice management company in the specialty field of anesthesia and pain management, we distinguish ourselves by providing optimal business tools to strengthen...
On-time case starts can make the difference between profitable and unprofitable operating rooms. There are multiple causes for late starts, among them clinical complications, unavailable instruments or supplies, unavailable laboratory reports or other paperwork, delays in room turnover and late arrivals on the part of surgeons, patients, and yes, anesthesiologists and nurse anesthetists.
Almost all of the problems listed above are within the control of the anesthesiology group in charge of managing the OR. A June 14th Outpatient Surgery Tip of the Day (www.outpatientsurgery.net) republished four tips to incentivize surgeons and anesthesiologists to arrive on time for scheduled cases. These tips originally appeared in the November 2010 issue of Outpatient Surgery. The article by Dan O’Connor was directed to readers who manage both types of physician, but the strategies can be implemented (or at least proposed) by a practice that provides an anesthesiologist-medical director.
Tip No. 1: Make wake-up calls. An...
Owners of ambulatory surgical centers (ASCs) often wish to receive a share of the professional fees paid to their anesthesiologists and nurse anesthetists. ASC owners and anesthesiologists and CRNAs have adopted—or at least proposed—numerous corporate and contractual structures over the last few decades to accomplish this transfer of revenues. The federal Anti-Kickback Statute (AKS), which prohibits a broad range of payments for referrals, has generally caused conservative lawyers to advise against such arrangements. Some attorneys and other advisors who are less risk-averse have helped their clients to go ahead.
The HHS Office of the Inspector General (OIG) has just provided some guidance on the issue. The guidance takes the form of an Advisory Opinion (No. 12-06) (posted June 1, 2012), which means that the decision is not binding on any parties, including the OIG. Nevertheless, the Advisory Opinion spells out how the OIG would apply the AKS principles to two common...