HHS Update to CRNA Administration of Pain Management

HHS Update to CRNA Administration of Pain Management

by abilling, May 10, 2013

WPS released an update to the CRNA administration of pain management.  We thought we would share with you that update.

Certified Registered Nurse Anesthetist (CRNA) Practice and Chronic Pain Management

Coverage in 2012

In 2012, Medicare coverage of CRNA services was more limited than Medicare coverage for services provided by other advanced practice nurses, such as nurse practitioners (NP) and clinical nurse specialists (CNS). This difference in coverage was due to differences in the Social Security Act (SSA). The SSA allows Medicare to pay for NP and CNS “services which would be physicians’ services if furnished by a physician,” provided the service is within the practitioner’s State scope of practice. However, in regards to CRNAs, the SSA only allows Medicare to cover and pay for “. . . anesthesia services and related care furnished by a CRNA, which the nurse anesthetist is legally authorized to perform, as such by the State in which the services are furnished.” Thus, Medicare may cover and pay only for “anesthesia services and related care” provided by CRNAs on an assignment-related basis, while NPs and CNSs may be paid for the full range of services covered by Medicare-the same as physicians-provided they are legally authorized to perform those services under State law.

In 2012, WPS considered for coverage anesthesia services billed directly by a CRNA. WPS Medicare also considered for coverage additional services as described by CMS Internet-Only Manual (IOM) 100-04 – Medicare Claims Processing Manual, Chapter 12, Section 140.4.3 – Payment for Medical or Surgical Services Furnished by CRNAs,Adobe Portable Document Format when those services were provided by the CRNA and related to anesthesia care. “Related to” was defined as occurring during the peri-operative period. Chronic pain management services were not considered for coverage when billed directly by the CRNA. Instead chronic pain services were considered for coverage when performed incident to a physician and billed under that physician’s NPI.

Coverage in 2013

In 2013, CMS has modified its regulations at 42 CFR §410.69External Link to define “Anesthesia and related care” under the statutory benefit for CRNA services to the following: “Anesthesia and related care means those services that a certified registered nurse anesthetist is legally authorized to perform in the state in which the services are furnished.” This broadening of the benefit category allows CRNAs to bill Medicare directly for all services that are included within the state scope of practice for CRNAs in the state in which the services are furnished.

Chronic pain management is an evolving field. As of January 2013, several states are debating whether to include pain management in the scope of practice for CRNAs. Given the variations in state scopes of practice, WPS anticipates that some CRNAs will be able to bill directly for chronic pain management services, while others will not. WPS Medicare recommends that all CRNAs contact their state licensing board for a determination of what services are included in their scope of practice.

The above article can be found at the following link…




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Reasonable attempts have been made to be accurate.  However, medical billing, collections, coding and compliance are part science, part art, and even experts sometimes differ.  Neither Anesthesia Billing, Inc., the editors, publisher, contributors, or consultants warrant or guarantee the information contained will be applicable or appropriate in all situations.  For information specific to your practice, consult a qualified professional.

The information included in this publication is provided, among other things, to alert you to legal developments and should not be considered legal advice.  Specific questions about how this information affects your particular situation should be addressed to your attorney.

Editor:  Philip Blann (pblann@anesthesiabilling.com).

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