On May 21, 2010, the Centers for Medicare and Medicaid Services (CMS) released Transmittal 59, which provides some of the clarifications ASA has sought from the Agency regarding the Interpretive Guidelines for the Anesthesia Services Conditions of Participation.
The transmittal makes two significant changes to the interpretive guidelines.
1. The definition of what is considered “immediately available” during the supervision of CRNAs and AAs was modified to allow an anesthesiologists to be considered “immediately available” if they are physically located in the procedure suite, rather than in the procedure room, as previously required.
2. With respect to the requirement for the post-anesthesia evaluation, the sentence that previously read, "For outpatients, the post-anesthesia evaluation must be completed prior to discharge” has been deleted. The effect of this deletion is that the post-anesthesia evaluation, while still required to be completed within 48 hours after surgery, does not need to be completed prior to discharge of the patient following outpatient surgery.
According to an Agency official, this transmittal represents a minor, preliminary clarification. Hence, further clarification from future transmittals may be forthcoming. ASA will continue to work with CMS to address ongoing concerns and we will provide further updates and clarifications as we receive them.
New CMS Transmittal