Payment Conditions for Anesthesiology Services
Definition of Concurrent Medically Directed Anesthesia Procedures
Concurrency is defined with regard to the maximum number of procedures the anesthesiologist is medically directing within the context of a single procedure and whether these 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 the remaining is a Medicare patient, this represents three concurrent procedures. The following example illustrates this concept and guides anesthesiologists in determining how many procedures they are directing.
Example: Procedures A through E are medically directed procedures involving CRNAs. The starting and ending times for each procedure represent the periods during which “anesthesia time” is counted.
Procedure A Begins at 8 a.m. and lasts until 8:20 a.m.
Procedure B Begins at 8:10 a.m. and lasts until 8:45 a.m.
Procedure C Begins at 8:30 a.m. and lasts until 9:15 a.m.
Procedure D Begins at 9 a.m. and lasts until noon.
Procedure E Begins at 9:10 a.m. and lasts until 9:55 a.m.
Procedure Number of Concurrent Medically Directed Procedures
A 2
B 2
C 3
D 3
E 3
From 8–8:20 a.m., the length of procedure A, the anesthesiologist medically directed two concurrent procedures, A and B.
From 8:10–8:45 a.m., the length of procedure B, the anesthesiologist medically directed two concurrent procedures. From 8:10–8:20 a.m., the anesthesiologist medically directed procedures A and B; from 8:20–8:30 a.m., the anesthesiologist medically directed only procedure B; from 8:30–8:45 a.m., the anesthesiologist medically directed procedures B and C. Thus, during procedure B, the anesthesiologist medically directed two concurrent procedures.
From 8:30–9:15 a.m., the length of procedure C, the anesthesiologist medically directed three concurrent procedures. From 8:30–8:45 a.m., the anesthesiologist medically directed procedures B and C; from 8:45–9 a.m., the anesthesiologist medically directed procedure C; from 9–9:10 a.m., the anesthesiologist medically directed procedures C and D; from 9:10–9:15 a.m., the anesthesiologist medically directed procedures C, D and E. Thus, during procedure C, the anesthesiologist medically directed three procedures at most.
The same analysis shows that during procedure D or E, the anesthesiologist medically directed three concurrent procedures at most.
A physician who is concurrently directing the administration of anesthesia to not more than four surgical patients cannot ordinarily be involved in furnishing 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 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 Medicare 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 and not reimbursed by Medicare.
