2017 HHS OIG Work Plan Includes Anesthesia Issues

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has posted its Work Plan for FY2017. The 2017 Work Plan includes two issues specific to anesthesia care.  These issues have been included in previous editions of the Work Plan.  ASA members are reminded to be certain that they provide anesthesia services consistent with Medicare requirements and that their documentation demonstrates that compliance.

The two issues as described in the 2017 OIG Work Plan are:

"Anesthesia Services – Noncovered Services
Medicare Part B covers anesthesia services provided by a hospital for an outpatient or by a freestanding ambulatory surgical center for a patient.  We will review Medicare Part B claims for anesthesia services to determine whether they were supported in accordance with Medicare requirements.  Specifically, we will review anesthesia services to determine whether the beneficiary had a related Medicare service.

Anesthesia Services – Payments for Personally Performed Services
Physicians must report the appropriate anesthesia modifier code to denote whether the service was personally performed or medically directed (CMS, Medicare Claims Processing Manual, Pub. No. 10004, 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 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 provided has furnished the information necessary to determine the amounts due (SSA § 1833(e)).  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."