OIG Posts 2015 Work Plan

The Office of Inspector General , U.S. Department of Health & Human Services (OIG) has released its 2015 Workplan.  Each year the OIG releases this report which provides notice of the issues it intends to review in the upcoming year. Payment for personally performed anesthesia services remains on the OIG’s Workplan.  ASA will again reach out to the OIG to offer assistance with understanding anesthesia coding issues

You may download a copy of the report.  The anesthesia-specific issue is described as follows:

Anesthesia services—Payments for personally performed services 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 anesthesia services reported on a claim with the “AA” service code modifier met Medicare requirements. Physicians report the appropriate anesthesia modifier code to denote whether the service was personally performed or medically directed. (CMS, Medicare Claims Processing Manual, Pub. No. 100-04, ch. 12, § 50) Reporting an incorrect service code modifier on the claim as if services were personally performed by an anesthesiologist when they were not will result in Medicare's paying a higher amount. The service code “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, whereas the QK modifier limits payment to 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.