Billing and Coding for Labor Analgesia: FAQs

On June 15, 2026, ASA held a one-hour webinar¹ entitled “Coding and Billing for Labor Analgesia” to give an update to the ASA Timely Topic² and to allow for a live Q/A period. This Timely Topic was created based on this Q/A session.

Note. Labor analgesia refers to CPT Code 01967 “Neuraxial labor analgesia/anesthesia for planned vaginal delivery (this includes any repeat subarachnoid needle placement and drug injection and/or any necessary replacement of an epidural catheter during labor). For ease of text, when “labor epidural” is used below, it includes all neuraxial techniques that can be used for labor analgesia.

1. Is placement of a labor epidural an emergency, that is, should the "E" modifier be used?
   
   As noted in the ASA Statement on ASA Physical Status Classification , “the addition of “E” denotes Emergency Surgery. An emergency is defined as existing when a delay in the treatment of the patient would lead to a significant increase in the threat to life and body parts.” Because placement of a labor epidural is typically performed when an anesthesia clinician is available, and the parturient may need to wait if the clinician is caring for another patient, labor epidural placement for a planned vaginal delivery is not considered an emergency and does not warrant use of the E modifier. However, if the patient's condition later requires an emergency cesarean delivery, the E modifier should be added at that time.
   
   The Statement also notes that ASA recommends that a parturient with an uncomplicated pregnancy be classified as ASA Physical Status II.³  
   
   
2. If a woman is taken for an emergency cesarean delivery because of persistent fetal bradycardia and there is a high risk of fetal demise if delivery is delayed, would ASA Physical Status V-E be appropriate? After all, ASA Physical Status V is defined as a patient who is not expected to survive without the operation, and the fetus may not survive without immediate delivery.
   
   No. The ASA Physical Status Classification System is intended to communicate the physical condition and comorbidities of the patient receiving anesthesia. In obstetric anesthesia, the patient is the mother. Therefore, the ASA Physical Status classification should be based on the mother's medical condition and not on the condition of the fetus.
   
   In this scenario, persistent fetal bradycardia and the risk of fetal demise may make the cesarean delivery an emergency, making the use of the emergency modifier ("E") appropriate. However, the mother's ASA Physical Status should be assigned based on her own clinical status and comorbidities. Fetal distress alone does not justify assigning ASA Physical Status V to the mother. Obstetrical co-morbidities examples by ASA Physical Status Class can be found in the ASA Statement on ASA Physical Status Classification⁴.
   
   
3. Given that the maternal care and delivery codes have been extensively revised for 2027, will there be any changes to anesthesia codes or the ASA Crosswalk?
   
   The previously bundled maternal care and delivery codes have been unbundled to better reflect current clinical practice, in which prenatal care and delivery services are often provided by different obstetric clinicians. There have been no changes to the anesthesia codes associated with obstetric care. In the 2027 ASA Crosswalk and Reverse Crosswalk, the revised maternal care and delivery codes will be mapped to the appropriate existing anesthesia codes. Therefore, while the obstetric codes have changed, the anesthesia codes and their reporting remain unchanged. 
   
   
4. When should anesthesia start and finish times be reported for labor epidural analgesia associated with a successful vaginal delivery?
   
   As noted in the ASA Relative Value Guide⁵ , “Unlike operative anesthesia services, there is no single, widely accepted method of accounting for time for neuraxial labor anesthesia services.” Regardless of the payment methodology used, anesthesia start and finish times should be determined and documented consistently for all labor epidural analgesia services.
   
   Anesthesia start time is defined the same way as for operative anesthesia services: it begins “when the anesthesia practitioner begins to prepare the patient for anesthesia services.” Therefore, anesthesia time begins before placement of the epidural catheter, as patient positioning, preparation and draping, performance of the time-out, and other activities necessary for placement are all part of the anesthesia service and are included in anesthesia time.
   
   As discussed during the webinar, anesthesia finish time for labor epidural analgesia is less clearly defined than for operative anesthesia services. However, it is generally accepted that anesthesia time should not end at the time of birth. Ending anesthesia time at delivery does not account for anesthesia care that may be required during the third stage of labor (delivery of the placenta) or during the fourth stage of labor (the immediate postpartum recovery period). A common practice is to end anesthesia time one hour after an uncomplicated vaginal delivery, even if the epidural catheter is removed later. 
   
   
5. For our largest payer, payment for labor analgesia is determined by base units plus face-to-face time with the patient. We are using anesthesia time pauses and resumes to capture only the time spent with the patient. Does this matter?
   
   Although this may be a pragmatic way to capture exact face-to-face minutes, it is generally not recommended for several reasons. First, pausing anesthesia time does not recognize the value associated with the clinical requirement that an anesthesia clinician remain available to manage the labor epidural throughout labor. Availability to evaluate, provide consultation, troubleshoot, and intervene when necessary is an important component of labor epidural management, even when the clinician is not physically present at the bedside. Second, using pauses and resumes prevents accurate measurement of the total duration of labor epidural services. Information regarding total labor epidural time is important when evaluating contracts and comparing different payment methodologies. For example, if a group is considering a contract that pays a fixed amount for specified time intervals, it may be difficult to assess the financial impact of the proposal if the underlying data do not reflect the total duration of labor epidural care from start to finish. Third, although the largest payer only pays face time, other payers may pay for availability or the total time. Even with a fixed payment cap on total time, using pause and resume will underestimate true total availability and reduce the time billed.
   
   With the widespread adoption of electronic health records (EHRs), there are now better methods for capturing face-to-face time. Most EHR anesthesia records allow clinicians to document specific patient-care events and associated activities, including face-to-face encounters. The anesthesia clinician can also document the total number of minutes of face-to-face time provided. EHR systems often aggregate these events and narrative documentation into a single view, making it easier for coders to identify and calculate face-to-face minutes while preserving an accurate record of the overall labor epidural service. 
   
   
6. How should anesthesia services be reported when a labor epidural is used for analgesia during labor and delivery and is later used for a postpartum bilateral tubal ligation?
   
   Consider the following scenario: A woman receives a labor epidural for analgesia during labor and has an uncomplicated vaginal delivery. The epidural catheter is left in place, and six hours later she undergoes an elective bilateral tubal ligation using the existing epidural catheter for anesthesia.
   
   In this situation, the labor analgesia service and the anesthesia service for the bilateral tubal ligation should be treated as separate anesthesia encounters. The anesthesia time associated with labor analgesia should end as if no tubal ligation is planned. The subsequent bilateral tubal ligation is a separate surgical procedure requiring its own anesthesia record, start time, stop time, and anesthesia CPT code assignment (00851, Anesthesia for intraperitoneal procedures in lower abdomen including laparoscopy; tubal ligation/transection). The base unit value for the anesthesia for the tubal ligation remains the same even with the indwelling catheter.
   
   
7. How should the following scenario be reported? A patient receives a labor epidural for analgesia during labor and has a successful vaginal delivery. Two hours after delivery, she continues to experience severe postpartum hemorrhage and is taken to the operating room for an emergency hysterectomy. Is 01962 the appropriate anesthesia code?
   
   Yes. Although the patient initially received epidural analgesia for labor and delivery, the hysterectomy is a separate postpartum surgical procedure performed after delivery has been completed. The labor analgesia care should be stopped as usual. The subsequent anesthesia for urgent hysterectomy following delivery⁶  should be reported as a separate anesthesia encounter using code 01962.A separate anesthesia record should be created for hysterectomy, including its own anesthesia start and stop times. Because the procedure is being performed for uncontrolled postpartum hemorrhage, the appropriate physical status modifier and emergency modifier ("E") should also be reported when supported by the patient's clinical condition and payer requirements.
   
   The use of the existing epidural catheter for hysterectomy, if clinically appropriate, does not change the reporting of the procedure as a separate postpartum anesthesia service.
   
   
8. Can you bill for an anesthesia consult if no anesthesia care is provided?
   
   It is possible and appropriate to bill for antenatal anesthesia consultation. However, in the situation where a pre-anesthesia evaluation is done but the patient delivers with no anesthesia, this is not billable. For more details, see ASA Statement on Antenatal Anesthesiology Consultation⁷ and the ASA Timely Topic “Distinguishing Between a Pre-Anesthesia Evaluation and a Separately Reportable Evaluation and Management Service”⁸.
   
   
9. Do epidural catheter replacements and epidural blood patch procedures generate additional billing units under most anesthesia payment methodologies?
   
   Epidural catheter replacement during labor analgesia DOES NOT generate additional anesthesia base units or constitute a separate billable anesthesia service. Catheter replacement is considered part of the overall management of labor epidural analgesia, and anesthesia time continues uninterrupted within the same anesthesia encounter.
   
   An epidural blood patch is different because it is a distinct procedure performed to treat a complication, most commonly a post-dural puncture headache. When medically necessary and appropriately documented, an epidural blood patch is typically reported as a separate procedure (CPT 62273).
   
   
10. Is there a limit to concurrency when a patient is taken to the operating room for cesarean section or a postpartum tubal ligation?
    
    When an anesthesiologist is medically directing surgical anesthesia cases, there is no limit to the number of labor epidural analgesia patients for whom the anesthesiologist may provide care. Placement of labor epidural catheters and periodic monitoring of labor epidural analgesia are specifically permitted activities while medically directing surgical anesthesia cases.

References

1. The recorded webinar will be available soon and posted at Coding Billing and Payment.
2. Vaidyanathan M. Coding and billing for labor epidurals. American Society of Anesthesiologists. January 2022. Accessed July 13, 2026. https://www.asahq.org/quality-and-practice-management/managing-your-practice/timely-topics-in-payment-and-practice-management/coding-and-billing-for-labor-epidurals
3. American Society of Anesthesiologists Statement on ASA Physical Status Classification System Anesthesiology Open. 2025;1(1):e0002. doi:10.1097/ao9.0000000000000002
4. American Society of Anesthesiologists Statement on ASA Physical Status Classification System Anesthesiology Open. 2025;1(1):e0002. doi:10.1097/ao9.0000000000000002
5. American Society of Anesthesiologists. 2026 Relative Value Guide®: A Guide for Anesthesia Values. P.31
6. American Society of Anesthesiologists. CROSSWALK® 2026: A Guide for Surgery/Procedure Codes and ASA Anesthesia Codes. American Society of Anesthesiologists; 2026
7. American Society of Anesthesiologists Committee on Obstetric Anesthesia. Statement on Antenatal Anesthesiology Consultation. American Society of Anesthesiologists. Approved October 15, 2025. Accessed July 13, 2026. https://www.asahq.org/standards-and-practice-parameters/statement-on-antenatal-anesthesiology-consultation
8. American Society of Anesthesiologists Committee on Economics. Distinguishing Between a Pre-Anesthesia Evaluation and a Separately Reportable Evaluation and Management Service. American Society of Anesthesiologists. November 2020. Revised March 2023. Accessed July 13, 2026. https://www.asahq.org/quality-and-practice-management/managing-your-practice/timely-topics-in-payment-and-practice-management/distinguishing-between-a-pre-anesthesia-evaluation-and-a-separately-reportable-evaluation-and-management-service