Although the specialty of Anesthesia is time-based and reimbursed using billable minutes, few practitioners are aware of all the nuances that charting requires for accurate billing and reimbursement. This article is intended to expound on this topic, using common clinical vignettes.
Anesthesia Start Time
The AMA and CMS define anesthesia start time as the moment in which an anesthesia provider is in personal attendance with a patient and begins preparing such patient for the induction of anesthesia, either in the operating room or the equivalent area (whichever is first).
In many instances, some form of sedation is given to patients in the pre-op holding area, prior to being wheeled into the surgical suite. A practice’s policy should be that anesthesia start time can begin in pre-op holding, if sedation is administered and charted accordingly within the anesthesia record.
Anesthesia End Time
The AMA and CMS define anesthesia end time as the moment in which an anesthesia provider transfers care of a patient over to recovery room personnel, typically in the Post Anesthesia Care Unit (PACU).
This clinical event should constitute anesthesia end time for practices, which will be corroborated by the anesthesia record end time and PACU notes “Anesthesia Care Transfer” timestamp.
Intraoperative Handoffs (Relief Time)
Providers should always document their respective start and end times for each case. If responsibility of the patient is transferred from one Anesthesiologist to a second relieving Anesthesiologist, each should document their individual times.
The same is true of CRNA relief. Billers typically file claims under the Anesthesiologist and/or CRNA with the most time in the case, with total minutes spent on patient care by all like-providers. For reporting purposes, all individual provider times are typically captured within a billing system.
Discontinuous Time
In the event that anesthesia time is discontinuous, practices should bill only for the segments of time in which an anesthesia provider is physically present and providing billable anesthesia time-based services (excluding labor epidural cases, as referenced below).
An example of discontinuous time would be a provider performing a preoperative intrathecal injection from 7:00-07:05 and subsequent anesthesia from 07:20-08:00. In this example, the total billable case time would be 45 minutes, since the patient’s anesthesia care was provided by anesthesia personnel for the first and third segments, with an RN caring for the patient during the middle 15-minute segment.
Invasive Monitoring Lines and Pain Blocks
In accordance with CMS guidance, practices should exclude procedural time for Lines (Arterial Lines, Central Lines and Swan-Ganz catheters) and Post-Op Pain blocks performed prior to Induction, from billable anesthesia minutes. Lines and Pain blocks placed after Induction do not require the subtraction of placement time from billable anesthesia minutes.
Patient transport time to and from the Critical Care Unit (CCU) or Intensive Care Unit (ICU)
As specified by the CMS National Correct Coding Initiative (NCCI), patient transport time from the CCU/ICU to the Operating Room (or vice versa) can be included in billable anesthesia minutes, when charted within the anesthesia record. Practices should bill for such time, when appropriate.
Labor and Delivery Time
Unlike surgical cases, labor epidurals are typically paid by insurance not based on face-to-face time, but rather, immediate availability time. It should be a practice’s policy that labor time can be billed from epidural placement to newborn delivery, as long as an anesthesia provider remains within the physical confines of the facility and is immediately available to the patient, upon request.
Practices should not bill for labor analgesia/anesthesia time in instances where no provider is on-site at the facility (i.e., call).
If an Episiotomy or Placental Delivery occurs after newborn delivery requiring the physical attendance of an anesthesia provider, end time can be extended until the conclusion of the respective clinical event, when the anesthesia provider is no longer in attendance. For “Labor to C-Section” cases, providers should always document both clinical events in the procedural section of the anesthesia record, to ensure correct billing (see below).
- Labor Epidural (CPT 01967 – 5 base units)
- Cesarean Delivery (CPT 01961 – 7 base units)
- Labor to C-Section (CPT 01967 – 5 base units + CPT 01968 – 3 base units)
*Although it’s rare, some insurance plans require that only “face-to-face” time be reported for labor epidural cases. Examples include Medicaid and Highmark BCBS plans. Due to this fact, it’s recommended that you survey your larger payors concerning their time reporting requirements.
Time Rounding
For sites using paper anesthesia records, providers should always chart anesthesia start and end times to the nearest one-minute increment, as opposed to rounding to the nearest 0 or 5-minute increment. This also applies to sites using electronic medical records, where providers have the ability to manually input or modify their anesthesia start and end times.
Hal Nelson, CANPC
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.
This educational guide was prepared as a tool to provide education for documentation and coding. It is not intended to affect clinical treatment patterns. The material provided is for informational purposes only. Efforts have been made to ensure the information within this document was accurate on the date of distribution. Reimbursement policies vary from insurer to insurer and the policies of the same payer may vary within different U.S. regions. All policies should be verified to ensure compliance. CPT® codes, descriptions and other data are copyright of the American Medical Association (or such other date of publication of CPT®).All Rights Reserved. CPT® is a registered trademark of the American Medical Association. Proprietary and confidential document. All rights reserved. No part of this document may be reproduced or used in any manner without the written permission of MSN Healthcare Solutions, LLC.
