Billing Exclusions For Anesthesia

A surgeon or physician may not bill for anesthesia performed at the same time he/she is performing the surgery. This includes conscious sedation codes 99143, 99144, 99145, 99148, 99149 and 99150.

Conscious sedation and local anesthetic when performed with a procedure are considered to be a part of the global surgical package and not separately payable.


certified Registered Nurse Anesthetists (CRNA) are master’s prepared advanced practice nurses.

CRNAs provide anesthetics to patients in every practice setting, and for every type of surgery or procedure.

CRNAs provide anesthesia in collaboration with surgeons, anesthesiologists, dentists, podiatrists, and other qualified healthcare professionals. Anesthesia administered by a nurse anesthetist is recognized as the practice of nursing. Anesthesia administered by an anesthesiologist is recognized as the practice of medicine. Regardless of whether their educational background is in nursing or medicine, all anesthesia professionals give anesthesia the same way.

CRNAs may either be self-employed or work for a physician or facility based practice. There are currently 33 states that do require physician supervision of a CRNA. The determination as to whether the CRNA requires supervision is based on the scope of practice and licensing requirements for the state in which they practice. (See Table 1 for state and federal specific requirements). In states where a CRNA is allowed to practice independently there still may be CRNAs who work under the supervision of an anesthesiologist  and should bill accordingly. It should be noted that CMS defers to state law regarding supervision of a CRNA though the federal requirement for Medicaid and Medicare states that a physician must supervise the CRNA

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