Anesthesia Compliance Plans

The Office of Inspector General released its Work Plan for fiscal year 2015. Anesthesia remains a target on its list of reviews for 2015. The item under scrutiny is billing for personally performed anesthesia service.

Compliance Programs

The Office of Inspector General (OIG) has given clear direction in the publication “Compliance Program Guidance for Individual and Small Group Physician Practices” on establishing a voluntary compliance plan. The intent of this initiative was to assist in preventing submission of erroneous claims or engaging in unlawful conduct involving the federal health care programs. By developing these compliance plans health care providers can use internal controls to better monitor the adherence to applicable statutes, regulations and program requirements.

Personally Performed Service

The OIG will review claims for personally performed anesthesia services to determine if the Medicare requirements are met. Claims for services personally performed by the anesthesiologist and submitted with the “AA” modifier results in higher payment for the anesthesiologist.The reimbursement is at a higher amount than the medically directed rate that limits reimbursement to 50% of personal performance.

The Medicare reimbursement rules are available in the Medicare Claims Processing Manual, Pub. No. 100-04, ch. 12, § 50. You can review the OIG 2015 Work Plan at

This is a good time to review your billing processes with an audit to insure that claims are submitted in accordance with the Medicare rules.

Be aware that it is the anesthesia provider’s responsibility to comply with the legal requirements and monitor the activity of its billing staff or outsourced billing company.

We Can Help

Anesthesia Compliance Consultants (ACC) will assist your organization with the creation of a compliance plan that covers the seven components. Our team of experienced professionals, crafts compliance plans consistent with regulatory, medical, billing and coding standards. Our professionals have been involved in the business of anesthesia compliance since 2002 and have the experience both legal and as anesthesia providers to fully comprehend the needs of anesthesia practices.