Lines Placed By SRNAs
An age-old billing mystery, partially solved
For those of you who have resided in the anesthesia RCM realm over the last couple of decades, there’s one billing question that has perplexed even the nation’s top experts. That is, the appropriateness of billing for invasive monitoring lines placed by Student Registered Nurse Anesthetists (SRNAs) or Student Anesthesiology Assistants (SAAs), under an Anesthesiologist’s or CRNA’s guidance.
What makes this question difficult to answer is the fact that CMS has no national policy statement on the matter, and that the existing teaching physician rules apply to residents at GME-accredited hospitals only. CMS instructs those seeking clarification to reach out to their Medicare Administrative Contractors (“MACs”) for an answer, a process that can prove to be both frustrating and time consuming. Due to this fact, consultants have been wise not to provide blanket statements endorsing the billing of these lines under the supervising provider, without additional research being conducted.
Anesthesia Billing Compliance
To this end, MSN Healthcare Solutions contracted with Vaughn and Associates out of Baton Rouge, Louisiana. The law firm’s principal, David Vaughn, is an expert in anesthesia billing compliance matters, and has a great track record of getting straight answers from Medicare on nebulous policy matters such as this. To help the greater anesthesia community at large, we’re sharing his responses below.
WPS J5 & J8 (IA, IN, KS, MI, MO, NE):
Allows for the billing by Anesthesiologists of line placements by SAAs (and by extrapolation, SRNAs) provided there is “direct 1 on 1 supervision of the student by the physician.”
Novitas JH (AR, CO, FL, LA, MS, NM, OK, TX):
Allows for the billing by Anesthesiologists and CRNAs of line placements by SRNAs and SAAs, with the caveat being that “the Anesthesiologist/CRNA must be present during the critical/key portion of the procedure and be immediately available during the entire procedure.”
Palmetto GBA J & M (AL, GA, TN, NC, SC, VA, WV):
Allows for the billing by Anesthesiologists and CRNAs of line placements by SRNAs and SAAs, providing that “the CRNA or Anesthesiologist was present for the entire procedure.”
Bill With Confidence
Although these responses represent only 27 of the 50 states, it certainly sets precedent for others to follow. If you’re in one of the 23 states not represented above, our guidance is to have your billing company engage a healthcare attorney to survey the MAC on your behalf.
It’s also practical to conduct similar surveys of your larger private payers. Once you know your insurance plans’ position, you’ll be able to bill with confidence and ensure that you’re getting paid for all the clinical work that you perform. The best practice is to include a teaching attestation on each line note affirming that the supervising provider was “present during all key portions of the minor surgical procedure.”
Hal has 30+ years of experience on both the payor and RCM side, with a focus in Anesthesia. He formerly worked as a senior claims approver at United Healthcare, as well as a compliance officer for multiple national anesthesia billing companies. His broad-based experience ensures that MSN clients have a resource for documentation and billing issues. His past speaking engagements include ASA, MGMA, Dartmouth, and Johns Hopkins.
