OIG Focused on reviews of Payment for Personally Performed Anesthesia Services in 2013. The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) publishes its Work Plan annually. The Work Plan summarizes new and ongoing reviews and activities that the OIG plans to pursue during the next fiscal year and beyond. The Work Plan is one of the tools that the OIG uses to protect the integrity of the Medicare program to help identify and prevent fraud, waste and abuse. A new addition to the Work Plan for 2013 is a review of Anesthesia for Personally Performed Services.
According to OIG it will review Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements. It will also determine whether Medicare payments for anesthesiologist services reported on a claim with the “AA” service code modifier met Medicare requirements. Physicians report the appropriate anesthesia modifier to denote whether the service was personally performed or medically directed. (CMS’s Medicare Claims Processing Manual, Pub. No. 100-04, ch.12, 50)
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 https://oig.hhs.gov/reports-and-publications/archives/workplan/2015/FY15-Work-Plan.pdf
The “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, and the “QK” modifier is used for medical direction of two, three, or four concurrent anesthesia procedures by an anesthesiologist. The QK modifier limits payment at 50 percent of the Medicare-allowed amount for personally performed services for the physician provided portion of the service. Payments are precluded unless the provider has furnished the information necessary to determine the amounts due.
Considering the addition of this item to the work plan it is a good time to review your documentation and claims to assure that you are in compliance with the Medicare billing guidelines for personally performed and medically directed anesthesia services.