Anesthesia Compliance Plans; Seven Keys to Success
The complexity of federal and state programs make a compliance program essential for all group practices. Your compliance plan implemented well and maintained through regular meetings and communications is your main line of defense, should your group become the focus of an audit. Without a compliance plan, you will be at the mercy of the payers and should expect huge penalties, potential revocation of Medicare provider certification and even jail time. There is no reason to take the associated risk. Consider compliance a regular part of doing business and invest the energy and resources required to sleep well at night knowing that your risk has been reduced.
Seven Keys to Compliance Success
- Internal monitoring and auditing needs to be performed on a scheduled basis by well trained and experienced auditors.
- There should be clearly written and well communicated compliance program and practice standards.
- Designate a compliance officer.
- Maintain a high quality training and education program for all staff members.
- Insure that the lines of communications are open and allow concerned employees to speak freely, without fear of reprisals.
- If a problem is identified, have a plan of action to investigate, and take corrective action if required.
- Enforce the compliance plan without exception.
Anesthesiologists should be aware of areas that will draw attention from governmental payers and Recovery Audit Contractors (RACs). Facet injections have been the subject of recent OIG reports. Anesthesia start and stop times and protocol for transfer of care have received recent attention from governmental payers also.
Got Anesthesia Relief? Document it
Anesthesia providers can save themselves a great deal of compliance risk simply by clearly documenting when one anesthesia provider relieves another on a case – especially when medically directing.
If you don’t explicitly document that another physician has relieved you in the OR, an audit could mistakenly show that you were out of the building or performing more than 4 concurrent cases when you were still supposedly medically directing the original cases.
How to do it. You should have a space on the anesthesia record for relief documentation. This could be as simple as two columns of lines, with the headings “Start Time” and “Stop Time.” The first anesthesiologist’s start time should match the anesthesia start time. A medically directing anesthesiologist fills in the time he assumes or passes off medical direction of a case, and signs the same line.
Common relief mistakes. Stay on the lookout for the following anesthesia relief errors:
- A medically directing anesthesiologist gives one of his CRNAs a lunch break. At that point, he’s trying to personally perform at the same time as he medically directs – breaking the rules of medical direction. Technically, it also breaks medical direction if you give your CRNAs bathroom breaks. Many anesthesia groups just decide not to document lunch breaks, which can cause other problems. In such a case, you could bill for the CRNA services until the lunch break, but you’d probably have to absorb the physician’s medical direction fee.
- A CRNA takes over a case from a physician who is personally performing. The case changes to a medical direction situation when the CRNA takes over, but that can be tough to document. When possible, an anesthesia practice should schedule CRNAs to relieve CRNAs and MDs to relieve MDs.
- A physician knows he’s broken medical direction, but chooses not to document, say, a line insertion, or five minutes when a CRNA he’s directing is out of the OR. The omission might not show up in a regular audit, but the government might be able to sniff it out in a more indepth investigation.
- Most anesthesia specific billing software does a good job of concurrency checking to insure that the documentation shows all providers were in the right place at the right times.
Stay compliant and keep deliverying the best anesthesia care available.
