FY13 HHS Inspector General Workplan to Include Review of Personally Performed Anesthesia Services

The U. S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) has posted notice of the issues it intends to review for FY2013.  When determining areas to include in the workplan each year, the OIG considers factors such as:

• mandatory requirements for OIG reviews, as set forth in laws, regulations, or other directives;
• requests made or concerns raised by Congress, HHS management, or the Office of Management and Budget (OMB);
• top management and performance challenges facing HHS;
• work to be performed in collaboration with partner organizations;
• management’s actions to implement OIG recommendations from previous reviews; and
• timeliness.

One of the Medicare Part B issues that the OIG will review concerns anesthesia services:

Anesthesia Services —Payments for Personally Performed Services (New)

We will review Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements. We will also determine whether Medicare payments for anesthesiologist services reported on a claim with the “AA” service code modifier met Medicare requirements. Physicians report the appropriate anesthesia modifier to denote whether the service was personally performed or medically directed. (CMS’s Medicare Claims Processing Manual, Pub. No. 100-04, ch.12, § 50) The service code “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, and the “QK” modifier is used for medical direction of two, three, or four concurrent anesthesia procedures by an anesthesiologist. The QK modifier limits payment at 50 percent of the Medicare-allowed amount for personally performed services claimed with the AA modifier. Payments to any service provider are precluded unless the provider has furnished the information necessary to determine the amounts due. (Social Security Act, §1833(e).) (OAS; W-00-13-35706; various reviews; expected issue date: FY 2013; new start)"

Download a copy of the 2013 OIG workplan.

If you receive any information that your claims may be under OIG review, please email Sharon Merrick, Director of Payment and Practice Management.  Additional questions?  Please also direct them to Sharron Merrick.