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CMS Updates Manual Regarding Payment for Medical or Surgical Services Furnished by CRNAs

On March 8, 2013, the Centers for Medicare and Medicaid Services (“CMS”) issued Transmittal 2668 (Change Request 8180) to Publication 100-04 (Medicare Claims Processing), rescinding and replacing Transmittal 2634 (January 11, 2013). Transmittal 2634 provided clarifications in the manual language to reflect revisions to 42 C.F.R. § 410.69. The newly-released Transmittal 2668 maintained all changes made by Transmittal 2634, but deleted two inadvertently retained sections: 140.1.1 and 140.1.2.

42 C.F.R. § 410.69, which went into effect January 1, 2013, defines and sets forth the requirements for certified registered nurse anesthetists (“CRNAs”) and anesthesiologist’s assistants (“AAs”). § 410.69 defines “Anesthesia and related care” as “those services that a certified registered nurse anesthetist is legally authorized to perform in the state in which the services are furnished.” An “Anesthetist” encompasses both CRNAs and AAs.

Transmittal 2634 amended Chapter 12 Section 140 and its subsections as follows:

• Defined “Anesthetist” consistent with 42 C.F.R. § 410.69, including CRNAs and AAs • Added “nonphysician” as clarification to the term anesthetist • Removed the applicable CRNA conversion factor from the calculation of the anesthesia services fee schedule for services on or after January 1, 1996 (i.e. after that date, the applicable CRNA conversion factor is no longer used in determining the fee schedule)
• Added “reasonable and necessary” to the medical or surgical services performed by CRNAs which will be paid for by CMS
Transmittal 2668 replaced Transmittal 2634, keeping all changes, but removing Sections 140.1.1 and 140.1.2, which were inadvertently retained by Transmittal 2634. These sections related to notifications/verifications of certification and renewal of certification of CRNAs and AAs by and between CMS, employers of CRNAs/AAs, and carriers. All other changes made by 2634 were retained by 2668.

For more information about Transmittal 2668 and its impact on your practice, or any other questions related to anesthesia generally, contact Abby Pendleton, Esq. at 248-996-8510 or visit www.thehealthlawpartners.com’s Anesthesia and Pain Specialty page.

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