Whomever said knowledge is power perhaps should have said accurate or true knowledge is power! Misinformation or “alternative facts” are rampant. It is difficult to believe that anyone would share information that isn’t accurate or fact based, but it happens. Whether intentional or not, one has to apply an idiom we heard as youngsters, and “learn to separate the wheat from the chaff.”
Recently, I listened to a speaker with over thirty years of experience in coding share information on a webinar that was extremely outdated. Prior to both 2004 and 2010, teaching anesthesiologists were unfairly penalized for teaching residents, as anesthesia was the only specialty financially penalized for teaching residents. During both time periods, only 50 percent of the allowed amounts were paid for teaching two residents and the allowed amount was based on the documented amount of time spent in each case.
According to the information provided in a 2024 webinar, the “Anesthesiologist received 100% reimbursement if they are supervising a single case with a resident” and “Anesthesiologist received 50% reimbursement if they are supervising 2 – 4 cases involving residents/CRNAs.” That is partially true—until 2010! Teaching guidelines last updated in MLN006347, dated November 2024, limit the number of cases to two concurrent anesthesia cases involving residents, not four concurrent cases.
Pursuant to the Department of Health & Human Services (DHHS) Centers for Medicare & Medicaid Services (CMS) Transmittal 1859, dated November 20, 2009, “Effective for services furnished on or after January 1, 2010, payment may be made under Section 139 of MIPPA based on the regular fee schedule amount for the teaching anesthesiologist’s involvement in the training of residents in either a single anesthesia case or two concurrent anesthesia cases. We are also applying this same policy if the teaching anesthesiologist is involved in one resident case that is concurrent to another case that is paid under the medical direction payment rules. However, the medical direction payment policy would apply to the concurrent case involving the certified registered nurse anesthetist (CRNA), anesthesiologist assistant (AA) or student nurse anesthetist.”
Those of you who read anesthesia industry alerts or keep up to date with information provided by the American Society of Anesthesiologists (ASA) will recall several articles that support this updated information and directly contradict the misinformation provided. It would be a financial loss and detrimental to your practice if the guidance provided during the webinar is or was followed. Until 2004, the CMS rules limited the physicians reported time units to the actual time spent in each of the two cases. After 2010, the CMS rule did not include the same language and allowed full base plus time to be billed for each case with a resident using the AA and GC modifiers. As indicated in the October 19, 2020, alert resourced below, “the teaching anesthesiologist has gradually gained greater reimbursement when involved in two resident cases,” although I prefer “greater payment” over the term “greater reimbursement.” I recall using the term “reimbursement” early on and having an anesthesiologist ask why they were being reimbursed!
Further, the ASA published a press release on November 9, 2009, providing scenarios to explain how anesthesia practices would be impacted by the approved changes as follows: “The teaching anesthesiologist receives 100% of the fee schedule amount for the following cases:
- The teaching anesthesiologist is involved in one resident physician case (which is not concurrent to any other anesthesia case);
- The teaching anesthesiologist is involved in each of two concurrent resident cases (which are not concurrent to any other anesthesia case); or
- The teaching anesthesiologist is involved in one resident physician case that is concurrent to another case paid under medical direction payment rules.”
Coders and billing staff place a lot of trust on those of us who provide continuing education. When sharing information with others, one has an inherent obligation to check current guidelines and make certain information being shared is accurate and up to date.
Suffice it to say that whether misinformation, as I believe this to be unintentional, or disinformation, and I’m certain this is not done intentionally or with malice, one cannot simply accept information provided as the gospel. When resources are not provided to support the information given, the onus will be on the meeting attendees or you, dear reader, to determine whether it is fact or fiction.
Resources:
https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R59SOMA.pdf
Kelly Dennis, MBA, ACS-AN, CANPC, CHCA, CPMA, CPC, CPC-I, has over 41 years of experience in anesthesia coding and billing and has been speaking about anesthesia issues nationally since 2002. She has a master’s degree in business administration, is a certified auditor, coder and instructor through the American Academy of Professional Coders. Kelly is an advanced coding specialist through the Board of Medical Specialty and served as lead advisor for their anesthesia board. Kelly also serves as a practice management and reimbursement consultant for the American Society of Anesthesiologists. She is a certified health care auditor and has owned her own consulting company, specializing in anesthesia, Perfect Office Solutions, Inc., since November 2001. She can be reached at kellyddennis@attglobal.net.