CMS Claims Edits Delayed for Ordering/Referring Providers
The Centers for Medicare & Medicaid Services (CMS) previously announced that, beginning January 3, 2011, if certain Part B billed items and services require an ordering/referring provider and 1)the ordering/referring provider is not in the claim, 2) is not of a profession that is permitted to order/refer, or 3)does not have an enrollment record in the Medicare Provider Enrollment, Chain and Ownership System (PECOS), the claim will not be paid. The automated edits will not be turned on effective January 3, 2011. CMS commented that thry are working diligently to resolve enrollment backlogs and other system issues and will provide ample advanced notice to the provider and beneficiary communities before implementing any automatic nonpayment actions.
MLN Matters Number: SE1011; Revised Related Change Request (CR) #: 6421, 6417, and 6696; Related CR Transmittal #: R642OTN, R643OTN, and R328PI; Implementation Date: N/A
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.
