ASA Regulatory Victory: Pre- and Post-Anesthesia Interpretive Guidelines

ASA heard from many of you on the challenges of implementing the December 2009 revisions to the CMS hospital interpretive guidelines with respect to pre- and post-anesthesia evaluations.  Based on your feedback, discussions among relevant staff, member volunteers and leadership, the ASA Regulatory team identified a strategy to achieve meaningful revisions to the interpretive guidelines that would alleviate member concerns. CMS issued new guidelines that alleviated many of the concerns ASA members expressed.

For pre-anesthesia evaluations:

CMS loosened the timing of the various elements that comprise the pre-anesthesia evaluation. You are now required to complete and document a review of the medical history and interview (if possible given the patient’s condition) and examine the patient within 48 hours prior to surgery.  The remaining requirements (notation of anesthesia risk, identification of potential anesthesia problems, additional pre-anesthesia data or information and development of the anesthesia plan) can now be performed up to 30 days in advance of the surgery, as long as you review and update (as necessary) within 48 hours of surgery.

For post-anesthesia evaluations:

Same day surgery – CMS now explicitly permits completion of the post-anesthesia evaluations after patient discharge, as long as it is still within the 48 hour timeframe.

ICU/post-operative sedation patients – CMS now clarifies that you document the post-anesthesia evaluation within 48 hours with a notation and reason documenting that the patient was unable to participate in the evaluation.

Long acting regional anesthesia patients – CMS now clarifies that the post-anesthesia evaluation is performed within 48 hours even if the intended affects of anesthesia have not worn off.

Many of these changes and clarifications used suggested language provided by ASA.

Click here to read the CMS issued Revised Interpretive Guidelines.

Click here to read a memo from CMS on the Revised Interpretive Guidelines.

Click here to read FAQs released by CMS on the Revised Interpretive Guidelines.