August 2002
Volume 66 |
Number 8
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| Compliance
Corner |
From questions sent to members of the Committee on Practice Management:
Q. "I was wondering if ASA was working on a model
compliance plan for the Health Insurance Portability and Accountability
Act (HIPAA) for groups that use outside billing services. Please
let me know if ASA will have a model plan or can recommend someone
who has done a plan like that for other groups. I have filed for
HIPAA extensions and have reviewed the lectures from last winter's
[ASA] Practice Management Conference."
A. We have not considered preparing a "compliance
plan" for the HIPAA standardized electronic transactions
rules. This is not an area that lends itself to a general compliance
blueprint or plan. Compliance here is a matter of your making
sure that your electronic claims will be in the right computer
format by October 2003.
If you were transmitting your own claims using your own systems,
then you would need to reprogram. Since you are using an outside
billing service, that service should already be far along in the
task of reprogramming its computers. This presupposes that the
billing agency has mastered the 800-page HIPAA Professional Claims
Implementation Guide, which it should know by the number "837."
Here is a question that will test the extent of the service's
knowledge: "How will you bill for base and time units?"
Proposed changes to the Implementation Guide are a problem in
this area, one that we are working hard to fix. (Many ASA and
Anesthesia Administration Assembly members participated in the
recent letter-writing campaign asking the Centers for Medicare
& Medicaid Services to preserve the practice of billing for units
and not just minutes – thank you!)
The point is that your key to compliance is to make sure that
whoever controls the submission of your electronic claims knows
what they are doing.
Medicare to Recognize Base Units for Add-on Anesthesia Codes
In the proposed rule on the Medicare Fee Schedule published in
the June 28, 2002 Federal Register, CMS announced its intent to
revise its handling of add-on anesthesia codes, i.e., the burn
and obstetric codes adopted by Current Procedural Terminology
in 2000 and 2001. ASA will support this proposal, and it is unlikely
that there will be any opposition.
When multiple surgical procedures are performed during a single
anesthetic, only the anesthesia code with the highest base unit
value is reported, but time is increased to reflect the combined
total of anesthesia time for all the procedures. When add-on codes
are involved, the payment should include base units and time units
for both the primary code and the add-on. CMS' proposal will make
this distinction between multiple procedures and add-on codes
and direct carriers to issue payment for add-on codes according
to the usual anesthesia system of base + time x the conversion
factor [Table
1].
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