egular visitors to the ASA Web site will recognize the title of this column from an alert posted in January. Regulations regarding who must perform the postanesthesia inpatient hospital visit and write the report have created such widespread hassles that we want every anesthesiology department to know that the Medicare rule has finally changed.

It is no longer necessary that the anesthesiologist personally write the follow-up note. Another physician, including a resident, a nurse anesthetist or an anesthesiologist assistant (in certain states) can perform the patient assessment and write the report within 48 hours after surgery. The medical staff bylaws must be amended to allow this delegation and describe the method or protocol by which anesthesiologists may arrange for a colleague, trainee or nonphysician anesthetist to provide and document the postanesthesia follow-up.

The full text of the regulation and the Centers for Medicare & Medicaid Services (CMS) Interpretive Guidelines and Survey Procedures appears in the box below. The entire Conditions of Participation manual for CMS hospital surveyors, known as the “State Operations Manual,” is available for download at <www.cms.hhs.gov/physicians/anesthesiologist/default.asp>.

As an aside, generations of ASA representatives have been asking CMS to make this change. There has never been any expressed opposition at all, just a process to follow. Please recall this example when you think that it should be easy to persuade the government to fix a problem!

Locked Anesthesia Carts, on the Other Hand

ifficulties created by the CMS requirement that anesthesia carts be locked when they are not in active use, even between cases with minimal turnover time, are ongoing — but there are signals once again that a solution to this problem is on the way.

The “Practice Management” column in the April 2004 NEWSLETTER explained that CMS hospital surveyors were interpreting the Conditions of Participation regulation stating “drugs and biologicals must be kept in a locked storage area” to mean that anesthesia carts must be locked. An ASA delegation headed by 2005 President Eugene P. Sinclair, M.D., had visited CMS to urge an interpretation consistent with our own policy on “Security of Medications in the Operating Room” <www.ASAhq.org/Washington/LockedCartPolicyFinalOct2003.pdf>. The meeting went well, and we had expected favorable Interpretive Guidelines to issue as early as May 2004.

It came as quite a disappointment that the Interpretive Guidelines instead specifically targeted anesthesia carts for the first time and stated: “If a cart containing drugs or biologicals is in use and unlocked, someone with legal access to the drugs and biologicals in the cart must be close by and directly monitoring the cart.” (For the full text of the Interpretive Guidelines and Survey Procedures, see §485.25[b][2] in the manual on the CMS Web site URL cited above.) This position is even less reasonable than the text of the postoperative note regulation; if it means that the anesthesiologist must be watching the cart instead of the patient, it can create a real threat to patient safety.

Informal contacts lead us to believe, however, that the proposed regulation correcting this interpretation is in the final stage of the approval process. For now the advice to hospitals cited for violating the locked-carts interpretation is still: Request reconsideration, then appeal to the CMS Regional Office and hope that the correction will be in place soon.

Two Surveys That You Will Love: Anesthesia Practice Costs, Anesthesia Fees

1. Cost Survey for Anesthesia Practices, 2004 Report Based on 2003 Data. (Medical Group Management Association [MGMA], 2004). For the first time, MGMA has published a comprehensive report on anesthesiology practice costs. The data in this report came from more than 100 single-specialty anesthesiology “organizations,” a 20.5-percent response rate. In the area of medical group participation in financial surveys, that is a good yield.

The report contains detailed statistics on many variables, including the following:

The tables are broken down per full-time equivalent physician and by care team model as well as by “all” practices. It seems safe to say that the MGMA survey team has made the maximum possible use of all the survey data obtained. The result is one tremendous resource for anesthesiology practice management.

The 2005 edition of the Cost Survey for Anesthesia Practices will be even more valuable with increased participation. ASA leadership recently approved our formal collaboration with MGMA in this venture. We will add our own Committee on Practice Management’s advice on the questionnaire to the successful 2004 design that reflected the considerable sophistication of the current and a recent past president of the MGMA Anesthesia Administration Assembly (AAA) (Shena Scott and Genie Blough). We will ask you (repeatedly, if necessary) to complete the questionnaire, or more specifically, to ask your administrator or billing service to do so.

The reward for our active support will be not just improved data but also an individual benefit for ASA members. Members who return completed survey forms will receive free copies of the book. Other ASA members will be able to purchase the book at the MGMA “affiliate” discount. MGMA is charging the general public $465 for the 2004 report; the affiliates’ price, which MGMA has generously extended to all ASA members, is $305. The MGMA member price is $255. To purchase copies of the 2004 book, contact MGMA at (877) 275-6462 or order online at <www.mgma.com>. The 2005 book is expected to be published in November.

2. 2005 ASA Fee Survey. We have just launched another fee survey, the fifth in our series of biannual surveys of commercial payments for anesthesiology services. The 2003 data are out of date, and we hope that the 2005 responses will be more valuable, and more numerous, than ever.

ASA members may receive more than one copy of the questionnaire in the next few weeks. Please make sure that your group returns a single questionnaire; giving the form to your practice manager or billing service for completion should help in that regard. Thank you in advance for your participation.

Note: This fee survey is designed to satisfy the conditions of the “antitrust safety zone” established jointly by the Department of Justice and the Federal Trade Commission in 1996.