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Medicare as a Second Language Policy

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Title: Medicare as a Second Language Policy


1
Medicare as a Second Language Policy Payment
Issues for CRNAsPamela K. Blackwell,
JDAssociate Director Federal Regulatory
Payment Policy
0909/08
2
Medicare as a Second Language
  • What makes it like a Second Language?
  • Acronyms (CMS, SGR, MEI, GPCI)
  • Formulas
  • Legal Language
  • Process
  • PATIENCE PRACTICE

3
Who sets practice payment policies for CRNAs?
  • AANA
  • CMS (Medicare) - Centers for Medicare/Medicaid
    Services, FDA, DEA, other federal agencies (e.g.
    payment rules)
  • Congress
  • State Government (e.g. licensure, certification)
  • Joint Commission
  • Healthcare Facilities Hospitals, Ambulatory
    Surgical Centers (ASCs), Community Access
    Hospitals (CAHs) (e.g. privileges)

4
Where do CRNAs Practice
  • Medicare CRNAs
  • CRNAs predominate where there are more Medicare
    beneficiaries. (GAO Rpt. 2007)
  • CRNAs predominate where the gap between Medicare
    and private pays is less. (GAO Rpt. 2007)
  • CRNAs are sole anesthesia providers in most rural
    hospitals.
  • CRNAs ensure rural hospitals can provide OB,
    surgical, trauma stabilization and pain
    management services.
  • CRNAs predominate in Veterans Hospitals and U.S.
    Armed Forces. (440 CRNAs, Dept. of Veterans
    Affairs)

5
Medicare Facts for CRNAs
  • CRNAs are recognized Medicare Part B
    providers,1989
  • Can bill Medicare directly for 100 of the
    physician fee schedule amount, just as can
    anesthesiologists
  • Medicare reimburses anesthesia professionals 2.4
    billion/year, most of which is for anesthesia
  • 1.7 billion for anesthesiology
  • 657 million for nurse anesthesia
  • Up 25 from 2005 level of 1.9 million
  • CMS, PFS Final Rule, 11/01/06
  • Federal Funding, Education
  • 3 million for nurse anesthesia education
    programs
  • Billions for GME
  • Congress considering cutting GME funding, so
    CRNAs self-financing their education could be a
    long-term advantage for the profession.

5
6
Medicare Latte Factor
Have you had your latte today?
7
Source CMS Actuary, National Healthcare
Expenditures Projections 2005-2015
8
Medicare Latte Factor cont.
  • Total US Healthcare Spent/year
    2.17 trillion, 16 of GDP
  • Medicare Budget
  • 19 of U.S. Budget
  • 420 billion/year
  • Total US Population 300 million
  • 12 oz Starbucks Tall Latte 2.70/cup

9
On average, every person in US contributes
1373/year to Medicare!
every person buying 508 lattes/year!
every person buying 1.3 lattes/day/everyday!
10
Medicare Medicaid
Medicare and Medicaid


Every person spends 6.70 /day/everyday!
2458/year! 2004 5/day, 1725/year 733
more/year!
11
Medicare Paperwork The Basics
  • Enrollment of CRNAs as Medicare
  • 855B Group - 65 pages
  • 855I Individual - 29 pages
  • CMS 1500 Form - 33 Total Elements
  • CPT Procedure and Diagnosis Coding
  • Who Does Your Coding? Degreed/Certified

12
The Layers of Medicare
  • Carriers/MACs (Medicare Administrative
    Contractor) A private company that has a contract
    with Medicare to pay your Medicare Part B claims,
    4 MACs
  • Blue Cross Blue Shield of Florida
  • Contractor - An entity that has an agreement with
    CMS to perform a project.
  • Noridian Administrative Services
  • Regional Offices - 10 - work closely with
    Medicare contractors in their assigned
    geographical areas.
  • CMS Centers for Medicare and Medicaid -
    Baltimore, MD

13
Medicare Part A vs. Part B
  • Medicare Part A - Conditions of Participation
  • MD supervision of CRNAs
  • Medicare Part B - Conditions of Payment
  • Medical direction, payment rules
  • Teaching payment rules

14
Medicare Part A
  • Requirements for hospitals to participate in
    Medicare program.
  • CRNAs (42 CFR 482.52)
  • Qualified anesthesia provider
  • Must be supervised by an operating practitioner
    or anesthesiologist who is immediately available
    if needed
  • State Opt-out of MD supervision
  • Can conduct pre-, intra-, and post-operative
    anesthesia reports

15
Medicare Part A cont.
  • Qualified anesthesia providers MD/DO,
    anesthesiologists, dentists, oral surgeons,
    podiatrists, CRNAs, AAs
  • Immediately available physical presence
    requirement
  • In the operative suite or labor delivery unit
  • Ability to immediately conduct hands-on
    intervention

16
Medicare Part A cont.
  • Immediately available does NOT mean
  • X MD has to have specific anesthesia training
  • X MD has to be specifically privileged to
    supervise CRNAs
  • X Supervising practitioner has to be an
    anesthesiologist
  • X Does not impose liability on surgeons who are
    the supervising MD
  • MD/DO, dentist, oral surgeon, podiatrist can be
    supervising practitioner.

17
Medicare Part A cont.
  • State Supervision Opt-out
  • Governor sends letter to CMS stating it wants to
    opt-out
  • Opting-out consistent w/ State law
  • Confirms w/ State Boards of Medicine Nursing
  • Opt-out effective once sent, Postcard
  • 14 Opt-out states - Alaska, Idaho, Iowa, Kansas,
    Minnesota, Montana, Nebraska, New Hampshire, New
    Mexico, North Dakota, Oregon, South Dakota,
    Washington, Wisconsin

18
Medicare Part A cont.
  • Medicare Interpretive Guidelines
  • Interpret Medicare Part A, Cond of Participation
  • Surveyors (Medicare, JCAHO, State Health Depts.)
    use to accredit healthcare facilities
  • Clarify immediately available supervision
    language
  • Physical presence req. problematic in rural
    hospitals, esp. for OB services (epidurals)
  • AANA working to ensure guidelines consistent
  • w/ Patient Access to quality care
  • CRNA practice

19
Medicare Part B
  • Requirements to be paid for services.
  • CRNAs are recognized - they or their employers
    should bill Medicare Part-B directly. (41 CFR
    414.60)
  • CRNAs are a REVENUE SOURCE Failure to Bill
    Medicare Part B reimbursement LOSSES
  • Medicare Q modifiers - (QX, QZ) who provided
    service

20
Medicare Part B Anesthesia Payment Formula
(The Relative Value Anesthesia Charge Structure)
Three Primary Components
  • Base Weight or Value of the procedure is
    expressed in Units
  • Time Value is expressed in 15 Minute Units
  • Anesthesia Conversion Factor (Jan-June08 CF
    19.96)

21

Anesthesia Payment Formula cont.
  • Anesthesia Conversion Factor
  • Anesthesia CF - Converts the value of provider
    services into a dollar amount. Determines
    Medicare payment for provider service in an area.
  • Jan-June 2008 19.96 (national average)

22
Anesthesia Payment Formula
  • Anesthesia Payment Formula
  • Total units (Base/Value units Time units)
  • X Conversion Factor (19.96)
  • Medicare payment in
  • Example
  • QZ (Non-medically directed) anesthesia service
  • 10 total units X 19.96 199.60
  • QX (Medically directed)
  • 10 total units X 9.98 99.80

23
Medical Direction - QX
  • Medical Direction When an anesthesiologist
    fulfills the following criteria for each of up to
    a maximum of 4 cases, Medical Direction of a CRNA
    takes place.
  • These are payment requirements
  • NOT quality of care standards. (63 FR 58843,
    11/02/98)
  • Medically Directed - QX (QK, QY)
  • CRNAs entitled to 50 of fee schedule for each
    case.
  • Anesthesiologist entitled to 50 of fee schedule
    for each case (42 CFR 415.110)

24
Medical Direction Criteria
  • (42 CFR 415.110)
  • For each patient, to receive payment for medical
    direction the physician must
  • (i) Perform a pre-anesthetic examination and
    evaluation
  • (ii) Prescribe the anesthesia plan
  • (iii) Personally participate in the most
    demanding aspects of the anesthesia plan
    including, if applicable, induction and
    emergence

25
Medical Direction Criteria
  • (iv) Ensure that any procedures in the anesthesia
    plan that he or she does not perform are
    performed by a qualified individual as defined in
    operating instructions
  • (v) Monitor the course of anesthesia
    administration at frequent intervals
  • (vi) Remain physically present and available for
    immediate diagnosis and treatment of emergencies
    and
  • (vii) Provide indicated post-anesthesia care.

26
Medical Direction Documentation Requirements
  • Condition of Payment
  • The anesthesiologist must document in the
    patients medical record that he/she has met all
    7 medical direction steps. (42 CFR 415.110)
  • Some insurers are moving away from paying for
    medical direction, could be good for CRNAs.
  • Additional paperwork requirements
  • Easier, and same cost to pay for a non-medically
    directed or personally performed service

27
Medical Direction Diagrams
11 Ratio -QY
21 Ratio -QK
MD
MD
50
50
50
50
50
50
50
50
50
50
CRNA
CRNA
CRNA
28
Medical Direction Diagram
41 Ratio -QK
MD
50
50
50
50
50
50
CRNA
CRNA
50
50
CRNA
CRNA
4 cases 400
29
Non-Medically Directed - QZ
  • CRNA entitled to 100 of the fee schedule

CRNA
CRNA
CRNA
CRNA
MD
100
100
100
100
100
5 cases 500
30
Supervision vs. Medical Direction
Supervision
Medical Direction
  • Part B
  • Individual practitioner payment
  • Rules of payment
  • NOT safety rules
  • CRNAs do NOT have to be medically directed
    to bill for services
  • Part A
  • Hospital participation
  • MD supervision required
  • Unless, state has opted-out

CRNAs in all states can bill as NON-medically
directed.
31
Billing for Anesthesiologist Assistants (AAs)
  • AAs cannot practice independently.
  • To bill for an AAs services the AA must work
    under the direct supervision of an
    anesthesiologist. (42 CFR 410.69)

32
CRNA Medicare Billing Requirements
  • Only a Certified nurse anesthetist can bill
    Medicare directly. (140.1.2 of the Medicare
    Claims Manual)
  • What does Medicare require to bill for services?
  • Certification
  • Recertification - Req. by AANA, assumed complete
    by CMS
  • NPI (National Provider Identifier) Used to be
    UPIN

33
NPI
  • Fall 2007 Medicare accepts only NPI
  • NPI Benefits
  • Each CRNA gets own NPI, linked to you forever
  • Where CRNA practices, (facility, geographic
    region) wont matter
  • Before Needed a different UPIN for every
    facility, region where you practice, slows
    reimbursement
  • Speeds up payment

34
Graduate/Student Nurse Anesthetists
  • Graduates/students nurse anesthetists are not
    assets to employers until they can generate
    revenue.
  • Graduate/student nurse anesthetists cannot bill
    for his/her services.
  • Employers of graduate/student nurse anesthetists
    cannot bill the graduate/students services.
  • Students/graduates should take certification exam
    ASAP!

35
Graduate/student billing cont.
  • CRNA is eligible to bill upon the date of
    certification. (Medicare Claims Manual, Ch. 12)
  • CRNAs can bill for services from official
    certification date to receipt of NPI.
  • Check w/ carrier if can hold claims and file
    claims when CRNA receives NPI or within one-year
    prior to being certified.
  • For non-Medicare claims, payment rules may vary.

36
Teaching Rules
37
Rules for Teaching CRNAs
  • A non-medically directed CRNA can bill Medicare
    for teaching a SRNA.
  • If a non-medically directed CRNA is teaching one
    SRNA  The CRNA can bill for 100 of the service
    if the CRNA remains continuously present for the
    entire procedure.

38
Rules for Teaching CRNAs cont.
  • 2. If the non-medically directed CRNA is
    teaching a SRNA in each of two rooms
  • The CRNA can bill for each of the two rooms.
  • Payment formula Base units discontinuous time
    multiplied by 19.96 (CF-anesthesia conversion
    factor). 
  • Discontinuous time (DCT) time in which the
    CRNA was present with the SRNA in the room or
    face to face with the patient.
  • CRNA can bill only for the time in the room
  • CRNA must be present in each room for pre- and
    post- anesthesia care.

39
Rules for Teaching CRNAs cont.
  • 3. If the CRNA is medically directed, and is
    teaching an SRNA in each of two rooms, the
    anesthesiologist receives 50 and the CRNA
    receives 50 of the total fee (medical
    direction).

40
Teaching Rules Diagrams
Base Discont. Time (CF) /each case
1.1 Ratio
2.1 Ratio
CRNA
CRNA
50 or 100
DCT
DCT
0
0
0
SRNA
SRNA
SRNA
CRNAs are non-medically directed.
41
Teaching Rules cont. Medical Direction
111 Ratio
421 Ratio
MD
MD
50
50
50
CRNA
CRNA
CRNA
50
50
50
SRNA
SRNA
SRNA
SRNA
SRNA
0
0
0
0
0
42
Teaching Rules for Anesthesiologists
  • If an anesthesiologist is teaching one resident
    or one SRNA 
  • The anesthesiologist can bill for 100 of the
    service if he/she remains continuously personally
    present for the entire procedure.
  • If anesthesiologist is not personally present w/
    SRNA Anesthesiologist can bill for only 50 of
    service.

43
Teaching rules cont.
  • 2. If anesthesiologist is teaching a SRNA in each
    of two rooms
  • Anesthesiologist can bill 50 of each service
    provided in each room
  • 3. If anesthesiologist teaching a SRNA in one
    room and is supervising or medically directing a
    resident, intern or CRNA in a second room
  • Anesthesiologist can bill 50 for SRNA service

44
Teaching rules cont.
  • 4. If the anesthesiologist is teaching a
    resident in each of two rooms
  • Can bill for each of the two rooms.
  • Payment formula Base units discontinuous time
    multiplied by 19.96 (CF-anesthesia conversion
    factor). 
  • Discontinuous time (DCT) time in which
    anesthesiologist was present with resident in the
    room or face to face with the patient.
  • Anesthesiologist can bill only for the time in
    the room
  • Anesthesiologist must be present in each room for
    pre- and post- anesthesia care.

45
Teaching Rules Diagrams cont.
1.1 Ratio
21 Ratio
MD
MD
50 or 100
50
50
0
0
0
SRNA
SRNA
SRNA
46
Teaching Rules Diagrams cont.
21 Ratio
MD
50
50
0
0
50
OR
SRNA
Res.
CRNA
47
Teaching Rules Diagrams cont.
Base Discont. Time (CF) /each case
1.1 Ratio
21 Ratio
MD
MD
50 or 100
DCT
DCT
0
0
0
Res.
Res.
Res.
48
Teaching Rules Legislation
  • H.R. 6331/Medicare Improvements for Patients
    Providers Act of 2008 (MIPPA)
  • Reformed anesthesiologist teaching rules can
    bill 100 of PFS when concurrently teaching 2
    anesthesiology residents.
  • Reformed CRNA teaching rules Req. CMS to
    establish teaching rules for CRNAs that are the
    same as anesthesiologist rules.
  • Next Steps
  • New Rules effective January 2010.
  • AANA with active CRNA support must work with CMS
    to establish equitable rules for CRNAs.
  • We Need Your Support!

49
06/25/07
Anesthesia Teaching Rules Diagrams - CURRENT
DCT
DCT
Medical Direction
DCT
DCT
CRNA
MD
MD
NON-medically directed CRNA
50
CRNA
SNA
SNA
Res.
Res.
50
Discontinuous time (DCT) time w/ SNA (student
nurse anesthetist)/Res.(resident) or w/ the
patient, and is 50 payment.
SNA
SNA
100
100
MD
ASA Proposal
MD
50
50
Res.
Res.
SNA
SNA
50
06/25/07
Anesthesia Teaching Rules Diagrams AANA PROPOSAL
Medical Direction
100
100
100
100
CRNA
MD
MD
NON-medically directed CRNA
50
50
CRNA
SNA
SNA
Res.
Res.
50
50
SNA
SNA
MD
100
100
SNA
SNA
51
Inserting Lines
  • Will Medicare pay CRNAs and anesthesiologists for
    teaching SRNAs how to insert lines and provide
    other medical and surgical services?
  • Other services may include insertion of Swan
    Ganz catheters, central venous pressure lines,
    pain management, emergency intubation, etc.
  • Answer It depends on the carrier.
  • CMS said that there is no prohibition to being
    paid to teach these services. HOWEVER, whether to
    pay or not is up to your Medicare carrier.

52
Iron Rules of Medicare
  • Just because it has a code, doesn't mean it's
    covered.
  •  
  • Just because it's covered, doesn't mean you can
    bill for it.
  •  
  • Just because you can bill for it, doesn't mean
    you'll get paid.
  •  
  • Just because you've been paid, doesn't mean you
    get to keep the money.
  •  
  •  

53
Iron Rules of Medicare cont.
  • There's always someone who gets the message and
    ignores it.
  • Just because you been paid once, doesn't mean
    you'll get paid again.
  •  
  • Just because you get paid in one state doesn't
    mean you'll get paid in another
  •  
  • You'll never know all the rules.
  •  
  • Not knowing the rules can land you in the
    slammer.

54
Why Congress the SGR are like aBride her
Wedding Budget
55
Sustainable Growth Rate (SGR)
  • Target Budget - Formula that sets a target for
    federal healthcare spending
  • Updated every year to account for increase in
    cost of healthcare goods services
  • Set by Congress, enforced by Medicare
  • Every year, Congress goes over budget

56
Increasing Costs to Medicare
  • Medicare costs are increasing exponentially each
    year
  • Sustainable Growth Rate (SGR) problem
  • Does not accurately reflect cost of healthcare
    services
  • Flat payment system - Does not reward for quality
    or efficiency
  • SGR Cliff
  • Each year Congress overrides SGR, smaller cut,
    AANA others support
  • 18 month fix costs 9.4 billion
  • Jan. 2010 Payment rates return to SGR rate,
    minus amount spent SGR fr 2004-2009
  • Result 10.6 Cut in Part B payments each year
    for 10 years to make up for overspending in
    2004-2009
  • MedPAC, determined that Medicare provider
    payments are adequate, appropriate access for
    Medicare beneficiaries

56
57
Re-Valuing of Anesthesia
  • Some relief for anesthesia providers
  • 2005 Medicare paid anesthesia 34 of private
    payments/67 below private
  • CMS Nov. 27, 2007 Final Rule
  • Successfully won 34 increase in value of
    anesthesia 25 boost in the anesthesia CF
  • Medicare paying 20 more for anesthesia in 2008
    than in 2007 though still less than private
    payers.

57
58
Presidential Congressional Elections
  • Impact on National Healthcare System
  • June 2008 - Congress and Administration delayed
    fully addressing the SGR issue.
  • Prediction - Democrats retain Congress, not
    enough in Senate to create working majority
    needed to push legislation through.
  • Republicans Healthcare should be market driven.
  • Provided by private insurance plans.
  • Government should have only a peripheral role so
    that market competition drives rates, quality and
    efficiency improvements.
  • Democrats Expand healthcare coverage to more or
    all Americans.
  • Struggle with how to make healthcare affordable
    and accountable.
  • Concerned with cherry-picking of healthier
    patients in a private payer driven market.

58
59
Election impact cont.
  • A reformed system must have incentives or
    requirements for everyone to purchase coverage to
    spread the risk pool.
  • Not everyone has to pay the same for coverage.
  • Medicare does a good job of spreading the risk,
    but is a poor price setter.
  • Any system-wide changes in the healthcare system
    will not happen quickly and are likely to be
    incremental in approach.
  • (Source Michael Hash, Tom
    Scully, JD, Sara Rosenbaum, JD)

59
60
Fab 5 Changes to Expect in Healthcare
  • Digitize healthcare system to increase
    efficiency, decrease redundancy and errors.
  • Requires nation-wide IT infrastructure.
  • Create value-based purchasing incentives for
    hospitals and providers (e.g. Physician Quality
    Reporting Initiative PQRI)
  • The reward for performance may not be more money
    - the reward could be not having your payments
    cut.
  • Addressing chronic care management and
    end-of-life costs, account for most healthcare
    dollars.
  • Source Michael Hash, Principal, Health Policy
    Alternatives Inc. (Fmr HCFA/CMS Secretary)

60
61
Fab 5 cont.
  • Conduct Comparative Effective Analysis
  • More evidence-based medicine to better determine
    who gets what services and payment amounts,
  • Best outcomes for the same or less cost.
  • Move away from fee-for-service to bundled
    payments to reduce cost. (CRNAs could risk losing
    identity and negotiating leverage.)
  • Who pays for healthcare services and costs?
    Taxpayers, government, insurers, patients,
    providers, hospitals...etc.

61
62
Success for CRNAs
  • Reduce Cost. Add Value.

CRNAs should be aware of policy and practice
management issues so they can apply the rules and
influence payment policies in their favor at
local/state/federal level.
62
63
Part B Link to Medicare Premiums
  • Payment formula links physician payment to
    Medicare premiums.
  • If Medicare pays providers more, then Medicare
    beneficiaries pay more.
  • 2005 Premium Cost 78/month
  • 2006 Premium Cost 125/month
  • Basic coverage (89) Drug benefit (36)
  • 1500/year/Medicare beneficiary

64
Pay for Performance
  • Pay for Performance (P4P) Medicare Part B
    payment based on quality of provider services.
  • 4 measures to evaluate provider performance
    quality.
  • Process, Structural, Patient Experience Outcome
  • Process practitioner providing care known to
    improve outcomes. Specific steps providers take
    to improve quality, steps well-trusted, based on
    research.

65
Pay for Performance measures cont.
  • Structural - ensure providers are capable of
    delivering quality care. Ex. Certification,
    recertification, continuing education.
  • Outcomes - how provider care actually affected
    the patient. Capture info
  • on clinical effectiveness,
  • safety.
  • Patient experience care met goals of patient,
    ensure patients involved in care and understand
    their role.

66
P4P measures cont.
  • CMS P4P Programs
  • Improve quality and efficiency, test Health IT
    systems, get hospitals and individual
    practitioners involved
  • Premier Hospital Quality Incentive Demonstration
  • 8.85 million in awards to hospitals that showed
    improvement just by reporting measures alone
  • Physician Quality Reporting Initiative (PQRI)
  • Makes reporting measures mandatory
  • Expands list of measures to report

67
Physician Quality Reporting Initiative (PQRI)
  • Providers who report measures 2009-2010 are
    eligible for a 2.0 increase in payments.
  • CRNAs eligible to report
  • 2009 PQRI CRNA-related Measures
  • Timing, administration of antibiotic prophylaxis
    in surgical patient
  • Prevention of Catheter Related Bloodstream
    Infection (CRBSI) Catheter Insertion Protocol/Ma
    ximum Sterile Barrier technique is followed
  • Preventive care and screening Body Mass Index
    (BMI)
  • Documentation and verification of current
    medications in the medical record
  • Patient co-development of treatment plan/plan of
    care

68
P4P measures cont.
  • What if patient should not have antibiotic? Do
    you get paid if you dont give the antibiotic?
  • Answer Yes, so long as you report.
  • Binary reporting allows practitioner to decide
    if antibiotic appropriate for each patient.
  • YES - you gave the antibiotic
  • NO - you didnt give antibiotic, cite why not
    appropriate in that case
  • Who determines anesthesia measures?
  • CMS, AMA Consortium, National Quality Forum
    (NQF), CDC, Private entities, AANA, ASA

69
P4P Role of CRNAs AANA
  • Participate in the development of anesthesia
    measures that improve patient safety and quality
    and that allow CRNAs to practice within their
    full scope of practice.
  • Build relationships with CMS and other decision
    makers
  • Participate in workgroups that develop measures
  • Member - AMA Consortium, Anesthesiology Work
    Group
  • Identify key AANA members, SRNAs/Education
    programs to contribute expertise and research
  • Educate members on P4P initiatives

70
Conditions of Participation - Updates
AANA Public Comments to CMS Practice
Improvements for CRNAs.
  • Authentication of Verbal Orders
  • Proposed rule CMS said verbal orders must be
    authenticated by prescribing practitioners.
  • AANA Comment CRNAs give verbal orders, but do
    not need prescriptive authority to give verbal
    orders. CMS proposed rule would exclude CRNAs
    from giving, authenticating verbal orders.
    Authentication crucial for patient safety and
    provider accountability.
  • CMS Response CMS agreed w/ AANA. CMS changed
    language so verbal orders must be authenticated
    by the ordering practitioner. CRNAs now
    included.
  • (71 Fed.Reg. 68672, Nov. 27, 2006)

71
CoP Updates cont.
  • Securing Medications
  • Proposed rule Controlled and Non-controlled
    substances must be locked at all times.
  • AANA Comment Agreed that drugs should not be
    accessible to those who would tamper, abuse or
    distribute drugs, but locking non-controlled
    substances at all times could jeopardize patient
    safety. (i.e. preparation of anesthesia carts)
  • CMS Response Agreed w/ AANA.
  • All drugs must be kept in a secure area, and
    locked when appropriate.
  • Controlled substances locked at all times. Area
    where actively providing patient care or
    setting-up for patient considered a secure
    area.

72
CoP Updates cont.
  • Post-Anesthesia Record
  • Proposed Rule Post-anesthesia can be completed
    by an individual qualified to administer
    anesthesia w/in 48 hrs. after surgery. Does not
    have to be the same person who provided
    anesthesia.
  • AANA Comment AANA agreed with proposed rule.
    Allows hospitals and anesthesia staff more
    flexibility in completing patients records and is
    consistent with rules for completing the
    pre-anesthesia record.
  • CMS Response Agreed w/ AANA. Any individual
    qualified to administer anesthesia can complete
    the post-anesthesia record.
  • NOTE CRNAs and anesthesiologists as qualified
    providers must play a real and active role in
    completing entire anesthesia record/evaluation.
    Students should not be completing record on their
    own, students are not qualified providers.

73
Where to go for HELP
  • AANA DC- http//www.aana.com/
  • Federal Medicare Legislative Regulatory Issues
  • Member section, Government Relations, Federal
    Issues
  • NEW! Medicare FAQs Answers to your most
    frequently asked Medicare payment questions.
  • http//www.aana.com/federalfaqs.aspx
  • Memos put complex rules in context
  • Include diagrams links to official Medicare
    documents
  • For use by you to advocate for your profession
    with your hospital administrators, other
    providers, insurers etc.
  • Email specific questions to info_at_aanadc.com
  • CMS/ Medicare Website
  • http//www.cms.hhs.gov/
  • Carrier info, NPI, P4P programs, Forms, Physician
    Fee Schedule, Payment rules

74
- Thank You -
  • AANA
  • Pamela K. Blackwell, JD
  • Associate Director
  • Federal Regulatory Payment Policy
  • Washington, DC
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