CMS Changes Conditions of Participation (CoP) for Anesthesia Services Part 3 of 4
Part III: Responsibilities of the Anesthesia Department
While many hospitals view Anesthesia Services as primarily a Medical Staff department, like Surgery or Gynecology, the CMS Conditions of Participation view it as similar to departments like Radiology, Food and Nutrition, and Rehabilitation Services. The emphasis lies in the provision of services rather than the positioning or reporting responsibilities set forth on an organizational chart. The Anesthesia Services department provides anesthesia, sedation, and analgesia as defined earlier. Staffing includes anesthesia providers, along with technicians or support staff members who assist in the management of the department. As a department of the hospital, Anesthesia Services has similar responsibilities for meeting the needs of patients, and improving care through the QA/PI process. Additional responsibilities are specified in the regulations.
Responsibilities of Anesthesia Director
The regulations require the Medical Staff to establish criteria for the qualifications of the Director of Anesthesia Services. The Director of Anesthesia department is responsible for:
- Developing policies and procedures governing the provision of all categories of Anesthesia Services, including under what circumstances an MD or DO who is not an anesthesiologist, a dentist, oral surgeon or podiatrist is permitted to administer anesthesia
- Defining the minimum qualifications for each category of practitioner who is permitted to provide anesthesia services
- Integrating Anesthesia Services into the QA/PI program of the hospital
Required Policies and Procedures
The goal for delivery of anesthesia services, centers around consistent use of resources to meet patient needs. Policies outline these expectations, and at minimum, hospitals must address:
- How Anesthesia Services needs will be met at all locations
- Clearly defined pre-anesthesia and post-anesthesia responsibilities
- Delivery of anesthesia services consistent with recognized standards—well designed policies would likely include:
- Patient consent
- Infection control measures
- Safety practices in anesthetizing areas
- Protocol for supporting life functions (cardiac, respiratory and hyperthermia emergencies)
- Reporting requirements (errors, incidents)
- Documentation requirements (both in the medical record and other sources such as narcotic logs)
- Equipment requirements (monitoring, inspection and maintenance)
Tips for Compliance
To comply with this section of the regulations, changes in policies and practices may be necessary. Begin by assuring that the following items have been established in policy or practice:
- Assure that Medical Staff documents clearly spell out the required items for privileging physicians and others practitioners for the types of anesthesia and complexity of procedures.
- Review policies to assure that each item noted in the Conditions of Participation can be found.
- Conduct an internal review of all sedation and anesthesia locations to assure consistent standards among all locations.
CMS Changes Conditions of Participation (CoP) for Anesthesia Services Part 2 of 4
Part II: Anesthesia Administration and Practitioners
According to the regulations, only the following practitioners can administer anesthesia:
- A qualified anesthesiologist
- A doctor of medicine or osteopathy (other than an anesthesiologist)
- A dentist, oral surgeon, or podiatrist who is qualified to administer anesthesia under State law
- A certified registered nurse anesthetist (CRNA), under the supervision of the operating practitioner or of an anesthesiologist who is immediately available if needed, unless in an opt-out state (As of July, 2009, opt-out states include CA, IA, NE, ID, MN, NH, NM, KS, ND, WA, AK, OR, SD, WI, MT.)
- An anesthesiologist’s assistant, who is under the supervision of an anesthesiologist who is immediately available if needed
The Medical Staff bylaws or rules and regulations must include criteria for determining the anesthesia service privileges to be granted to an individual practitioner and a procedure for applying the criteria to individuals requesting privileges for any type of anesthesia services, including those not subject to the anesthesia administration requirements (sedation). The hospital’s Governing Body must approve the specific anesthesia service privileges for each practitioner who furnishes anesthesia services, addressing the type of supervision required, if any. The privileges granted must be in accordance with state law and hospital policy.
The type and complexity of procedures for which the practitioner may administer anesthesia must be specified in the privileges granted to the individual practitioner. When a hospital permits operating practitioners to supervise a CRNA administering anesthesia, the Medical Staff bylaws or rules and regulations must specify for each category of operating practitioner, the type and complexity of procedures that category of practitioner may supervise. However, individual operating practitioners do not need to be granted specific privileges to supervise a CRNA.
Tips for Compliance
To comply with this section of the regulations, changes in policies and practices may be necessary. Assuring that all areas have been addressed is the only reliable way of avoiding violations on future surveys. Begin by assuring that the following items have been established in policy and practice:
- Define what privileges are required for each level of anesthesia services, including sedation and monitored anesthesia care.
- Align policy and practice regarding the appropriate level of supervision for non-physicians permitted to administer anesthesia under supervised situations.
- Define criteria for determining the anesthesia services privileges for individual practitioners, including those that may administer only sedation.
If the hospital will permit anyone other than an anesthesiologists to supervise a CRNA administering anesthesia, specify in the Medical Staff bylaws or rules and regulations, for each category of operating practitioner, the type and complexity of procedures that category of practitioner may supervise.
- On an ongoing basis, assure that the practices occurs as designed:
- The governing body shows approval of the specific anesthesia privileges granted to individual practitioners and any type of supervision required.
- If operating practitioners are allowed to supervise CRNAs, then define the privileges required to permit this supervision and the type and complexity of procedures where allowed.
