Within the next month, the Centers for Medicare and Medicaid Services (CMS) is expected to finalize the proposed Medicare Physician Fee Schedule for 2013. In the rule, CMS proposes to expand the definition of CRNA services to include “medical and surgical services that are related to anesthesia and that a CRNA is legally authorized to perform by the State in which the services are furnished.” Recognizing that several state legislatures have passed or are contemplating legislation that includes pain management within the scope of practice of Certified Registered Nurse Anesthetists (CRNAs), CMS rationalized its proposed changes on the basis that its new definition of CRNA services would allow for flexible application to the varying scopes of practice across states.
In recent years, as the specialty of pain management developed and the scope of CRNA practice evolved, there has been a lack of clarity and uniformity in how Medicare Administrative Contractors (MACs) interpreted the Medicare provisions relating to CRNA services that qualified for reimbursement. The proposed 2013 Physician Fee Schedule establishes a definitive answer. Essentially, if the fee schedule is passed as proposed, CRNAs will be reimbursed for those pain management services provided that are within the scope of their practice as defined by the state in which they practice. CMS cautions, however, that not all CRNAs practicing in states that permit CRNAs to perform pain management services have the requisite education or training. As with all other practitioners, CRNAs are responsible for obtaining the necessary training for all services furnished to Medicare beneficiaries.
The proposed rule triggered a nationwide grassroots opposition campaign by the American Society of Anesthesiologists (ASA). Citing the complexity of chronic pain procedures and advanced education and training required for safe administration of medication therapies, the ASA contends that current restrictions on CRNAs are in the best interest of patient safety. Conversely, the American Nursing Association (ANA) asserts that accreditation standards for CRNA programs include advanced education and training in treatment of chronic pain sufficient to develop proficiency in pain management practice. With the proliferation of mid-level practitioners in recent years, driven by a strained economy and propelled by healthcare reform, the scope of practice of non-physician providers will continue to evolve. CMS’s proposed 2013 Physician Fee Schedule represents simply another instance of this process.
For more information regarding the proposed Physician Fee Schedule or issues related to anesthesia and pain management, please contact Abby Pendleton, Esq. at (248) 996-8510 or visit The HLP website.