As HLP reported, in April, CMS requested that the RAC for Region D remove an anesthesia care package it had posted to its website. Now, the issue has been re-posted, with some changes:
Under NCCI Edit rules, the anesthesia care package consists of preoperative evaluation, standard preparation and monitoring services, administration of anesthesia, and post-anesthesia recovery care. Anesthesia CPT codes 00100 to 01999 include Evaluation & Management (E&M) services rendered on the day of the anesthesia procedure. If the only service provided is management of epidural/subarachnoid drug administration, then an E&M service should not be reported in addition to CPT code 01996.
The above lacks clarity around two issues: (1) whether this refers to E&M services provided only on the day of the procedure and E&M services billed with 01996; and (2) whether this is being treated as automated or a complex review. As you may recall, CMS directed the removal of the issue when it was written more broadly to include all E&M services billed before and after anesthesia.
You can view the posting by clicking “next” to page 2 of this RAC Info page.
For more information on anesthesia and RACs, visit the HLP’s RAC Page or contact Abby Pendleton, Esq. at (248) 996-8510 or (212) 734-0128, visit the RAC specialty page, or the HLP website.