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November 10, 2015

Avoiding Anesthesiology Billing Errors that Lead to RAC Audits

November 10, 2015

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Anesthesiology providers are some of the more vulnerable providers when it comes to Medicare audits, due to the complex nature of not only delivering care, but billing and coding for any procedure, as well as calculating timing.

Because of this vulnerability, the federal government has been particularly aggressive toward anesthesiology providers, especially since the Recovery Audit Contractors (RAC) program was mandated for all 50 states in 2011.

Avoiding a costly RAC audit – the base penalty per audited claim is $11,000 plus three times the claim amount plus legal fees – is of paramount importance for any anesthesiology provider. One way to mitigate potential disruption is to be aware of various errors that can result in RAC audits.

Here are a few categories of potential errors that can leave a practice vulnerable to the aggressive auditing process.


Calculating timing for a procedure for an anesthesiologist practice can be difficult, and because of this, there are plenty of opportunities to make an error that can result in a penalty.

For example, a practice can get in trouble for a lack of monitoring in the practice area that supports the time that was submitted for the claim. Additionally, practices can get in trouble for rounding time, being vague about start and stop times, including ancillary services during the anesthesia time, and billing for time begun prior to “in room” time and after “out of room” time.

Proper anesthesiology billing means being precise about the time spent on the procedure and ensuring that all timing on claims is accurate and proper.


By far, one of the most common errors that leads to RAC audits is incorrect coding.

It is crucial that codes are entered correctly for every applicable procedure. Since the advent of ICD-10, this is even more difficult because of the added complexity of the new codes.

It’s not enough to just supply the correct codes. There also needs to be proper documentation of all aspects of the procedure being performed in order to support the codes being claimed. Also, be careful not to “upcode” or use a higher code in order to increase the amount of the bill. That is a red flag that auditors are searching for when they review claims records.


Inconsistencies in documentation are some of the most frequent causes of billing errors. Documentation showing that a physician was in two places at the same time, for example, can spark an audit. A CRNA being documented with case times that overlap is another example. Having a service recorded on a billing slip but not recorded on the anesthesia record is a potential red flag that auditors can notice.

Proper documentation is essential. Most practices focus on proper coding and timing but lack the proper documentation to support all claims and remove inconsistencies from the record.

Ensuring Error-Free Anesthesiology Billing

The best way to ensure a practice avoids costly RAC audits is to put into place measures that lead to error-free billing.

Hiring an anesthesiology billing provider is one of the best ways to avoid audits and liability. Contact Medical Business Management for more information on removing errors and coding and billing correctly to maximize revenue collection and minimize the risk of an untimely and unprofitable audit.

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