Concurrent Medically Directed Procedures
Concurrency is defined with regard to the maximum number of procedures that the physician is
medically directing within the context of a single procedure and whether the other procedures
overlap each other. Concurrency is not dependent on each of the cases involving a Medicare
patient. For example, if an anesthesiologist directs three concurrent procedures, two of which
involve non-Medicare patients and one Medicare patient, this represents three (3) concurrent
cases.
The following example illustrates this concept and guides physicians in determining how many
procedures are directed:
Procedures A through E are medically directed procedures involving CRNAs. The starting and
ending times for each procedure represent the periods during which anesthesia times are
counted.
Procedure A begins at 8:00AM and ends at 8:20AM
Procedure B begins at 8:10AM and ends at 8:45AM
Procedure C begins at 8:30AM and ends at 9:15AM
Procedure D begins at 9:00AM and ends at 12:00 noon
Procedure E begins at 9:10AM and ends at 9:55AM
Procedure Number of ConcurrentMedically Directed Procedures Base Unit Reduction%
A 2 10%
B 2 10%
C 3 25%
D 3 25%
E 3 25%
A physician who is concurrently directing the administration of anesthesia to not more than four
(4) surgical patients cannot ordinarily be involved in rendering additional services to other patients. However, addressing an emergency of short duration in the immediate area, administering an epidural or caudal anesthetic to ease labor pain, or periodic, rather than continuous monitoring of an obstetrical patient, does not substantially diminish the scope of control exercised by the physician in directing the administration of anesthesia to the surgical patients. It does not constitute a separate service for the purpose of determining whether the medical direction criteria are met. Further, while directing concurrent anesthesia procedures, a physician may receive patients entering the operating suite for the next surgery, check or discharge patients in the recovery room, or handle scheduling matters without affecting fee schedule payment.
However, if the physician leaves the immediate area of the operating suite for other than short
durations or devotes extensive time to an emergency case or is otherwise not available to respond
to the immediate needs of the surgical patients, the physician’s services to the surgical patients
are supervisory in nature. No fee schedule payment is made.
The examples listed above are not intended to be an exclusive list of allowed situations. It is
expected that the medically-directing anesthesiologist is aware of the nature and type of services
he or she is medically directing, and is personally responsible for determining whether his
supervisory capacity would be diminished if he or she became involved in the performance of a
procedure. It is the responsibility of this medically-directing anesthesiologist to provide services
consistent with these regulations.
