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May 6, 2022

The High Cost of Bad Billing: The Dangers of Incorrect Documentation for Anesthesia Services

May 6, 2022

There are no do-overs in coding and billing for anesthesia services. You get one chance, and you have to get it right. Close only counts in horseshoes and hand grenades, as they say. The cost of incorrect documentation can be high - both in lost reimbursement and in non-compliance. You also can’t rely on someone else to do it for you. The central billing offices of hospitals and health systems normally don’t understand anesthesiology’s unique requirements or have the necessary skill sets. Don’t risk your bottom line because of billing mistakes!


Why Anesthesia Billing is Different

Reimbursement for anesthesiology procedures is calculated: base units x local conversion factor + anesthesia time. (And if this doesn’t sound familiar to you, we can help!) There are three parts to this equation, therefore, there are three places for error to creep into your billing logistics. 

  • Coding Complications - Most physician specialties have a limited number of codes. Anesthesia involves nearly all of the 13,000+ procedure codes because anesthesia is involved in nearly all of these procedures in the operating room. This increases the chance of error immensely. 
  • Accurate Time-Keeping - Most hospital services are reimbursed with fixed rates that correspond to current procedural terminology (CPT) codes. For anesthesiology, reimbursement is not fixed but is based on the amount of time spent in providing care. Including accurate and precise start and stop times is critical. 
  • Detailed Documentation - The less detail you include in documenting the procedure, the less likely you are to receive full reimbursement. A lack of detail could lead to the procedure applying to more than one CPT code option - in this case, it will always be reimbursed at the option with the lowest amount. You could be leaving money on the table simply by not describing your procedures in enough detail when billing and coding. 
  • Changes During the Procedure - If a procedure has to switch from monitored anesthesia care to general anesthesia mid-procedure, it will be billed at the same rate as long as you use the same modifier. Changing techniques mid-procedure is accepted as long as it’s documented, and will not change the final reimbursement amount. 


Compliance Red Flags

CMS can penalize your practice for continual non-compliance. Here are a few red flags that can lead to an audit:

  • Precision Matters - A misrecording of even 10 minutes will lead to only partial reimbursement of a time unit. These add up over the long run. 
  • Concurrency - You can medically direct and receive full payment for up to four procedures at a time, but look out for overlaps of other supervised cases. Payments are lowered if there are five concurrent procedures or more at a time. By default, your billing system should check for this, but it often requires manual adjustment. 
  • Medical Direction - Watch out for the definition of this one. If CRNAs and anesthesiology assistants are being supervised and the actions aren’t marked as completed by a coder, this represents unintentional fraud. It can also push a case into concurrency, as discussed above. 
  • Modifiers - These are important and indicate the level of anesthesiologist supervision. Accidental overbilling is watched closely by the Medicare Recovery Audit Contractor (RAC) program. Violations can lead to fines and fees. 


How to Prevent Billing Errors

Get a calendar, and make sure you have reminders set at regular intervals for a billing and coding professional to engage in an audit of your practice’s coding and billing standards. These professionals can ensure all your billers and coders are up-to-date on current CMS changes

CMS changes codes and definitions quite frequently, so ongoing education is paramount. Making sure the billing software you are using is up-to-date is also important. Changing systems that feel set in stone is hard, but necessary to avoid a loss of revenue or penalties for non-compliance.

If you need help making sure you are up to speed, contact us!



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