Health Law Alert. Supervision Requirements for CRNAs in Indiana
|
|
- Denis Barber
- 8 years ago
- Views:
Transcription
1 Health Law Alert March 31, 2006 About Hall Render Hall, Render, Killian, Heath & Lyman is a full service health law firm with offices in Indiana, Kentucky, Michigan and Wisconsin. Since the firm was founded by William S. Hall in 1967, Hall Render has focused its practice primarily in the area of health law and is now recognized as one of the nation's preeminent health law firms serving clients in 40 states. For more information visit Office Locations Indiana Offices Downtown One American Square Suite 2000 Indianapolis, IN (317) North Office 8402 Harcourt Road Suite 820 Indianapolis, IN (317) Kentucky Office 614 West Main Street Suite 4000 Louisville, KY (502) Michigan Office Columbia Center, Suite West Big Beaver Road Troy, MI (248) Wisconsin Office 411 E. Wisconsin Avenue Suite 900 Milwaukee, WI (414) Contact Us hallrender@hallrender.com Supervision Requirements for CRNAs in Indiana Adele Merenstein Timothy C. Lawson Executive Summary In recent months IHHA General Counsel has become aware of increasing comments from regulatory and/or accrediting body surveyors with regard to the appropriate supervision of certified registered nurse anesthetists ("CRNAs") in Indiana hospitals. In one particular case, a Healthcare Facilities Accreditation Program ("HFAP") accredited hospital was issued a Deficiency Assessment for failing to "properly supervise" its CRNAs, in violation of HFAP Critical Access Hospital ("CAH") Surgical Services Standards and Medicare Conditions of Participation for Hospitals ("CoPs"). Another HFAP accredited hospital, a non-cah facility, recently received a similar citation. While appropriate supervision of CRNAs may not be unduly burdensome for larger hospitals who have anesthesiologists on staff, smaller hospitals are challenged because supervising anesthesiologists (or other physicians willing to assume the responsibility) are scarce or simply unavailable. In light of recent regulatory and accreditation activity in this area, this Memo will review the supervision requirements for CRNAs under Indiana Hospital Licensure Rules, Medicare CoPs for Anesthesia Services, HFAP and Joint Commission on Accreditation of Healthcare Organizations ("JCAHO") standards. Detailed Analysis I. Indiana Hospital Licensure Rules for Anesthesia Services. The Indiana Hospital Licensure Rules ("Rules") address the provision of anesthesia services in a hospital. 410 IAC states as follows: Anesthesia shall be administered by those privileged by the medical staff who are: i. An anesthesiologist; ii. A qualified physician with appropriate training, experience and privileges;
2 iii. iv. A dentist, oral surgeon or podiatrist who is qualified to administer anesthesia under state law; A CRNA who is under the direction of the operating practitioner or of a qualified physician who is immediately available if needed. (Emphasis added). The Rules make it clear that a CRNA may practice either under the direction of the "operating practitioner" or, alternatively, under the direction of a qualified physician who is immediately available. The definition of "operating practitioner" includes professionals other than physicians (M.D.s or D.O.s) such as podiatrists and dentists. I.C defines a "practitioner" as an individual who holds: i. An unlimited license, certificate, or registration; ii. iii. iv. A limited or probationary license, certificate, or registration; A temporary license, certificate, registration or permit; An intern permit; or v. A provisionary license, issued by the board regulating the profession in question, including a certificate of registration issued under I.C Under the Rules, CRNAs may perform epidurals, outside the presence of an operating practitioner or physician, so long as one or the other is immediately available if needed. The "immediate availability" standard will be discussed in Section II below. II. Medicare Hospital Conditions of Participation ("CoPs") for Anesthesia Services (42 C.F.R (a)). The CoPs provide in pertinent part as follows: Standard: Organization and staffing. The organization of anesthesia services must be appropriate to the scope of the services offered. Anesthesia must be administered by-- (1) A qualified anesthesiologist; (2) A doctor of medicine or osteopathy (other than an anesthesiologist); (3) A dentist, oral surgeon, or podiatrist who is qualified to administer anesthesia under State law; (4) A certified registered nurse anesthetist... who, unless exempted in accordance with paragraph (c) of this
3 section [via a letter sent by the Governor of a state requesting a state exemption from the CRNA supervision requirement] is under the supervision of the operating practitioner or of an anesthesiologist who is immediately available if needed; or (5) An anesthesiologist's assistant... who is under the supervision of an anesthesiologist who is immediately available if needed. (Emphasis added). According to Captain David Eddinger, the lead hospital survey and certification analyst of the survey central office of CMS, and the drafter of the CoP Interpretive Guidelines, an "operating practitioner" is not limited to doctors of medicine and osteopathy. The term "operating practitioner" also encompasses podiatrists, dentists, oral surgeons and other practitioners who "operate." Thus, podiatrists, dentists, and oral surgeons may supervise CRNAs. As a practical matter, in smaller hospitals that do not have an anesthesiologist on staff, and in the absence of the operating practitioner (i.e., the patient's attending physician or other practitioner), the emergency department physician ("ED physician") may be the only physician available to supervise the CRNA in the administration of an anesthetic procedure such as an epidural. Under these circumstances, the ED physician could provide the necessary supervision for the CRNA to administer the anesthesia prior to the attending physician arriving at the hospital, assuming the ED physician is "immediately available" if necessary. While Interpretive Guidelines A-0417 for 42 C.F.R appear to require that a hospital privilege an operating practitioner to supervise a CRNA, according to Captain Eddinger of CMS, this is not the case. Captain Eddinger has had discussions with HFAP administrative personnel and surveyors about this issue because HFAP has cited hospitals for failing to privilege the operating practitioners for their supervisory responsibilities for CRNAs. Captain Eddinger has clarified that the privileging of operating practitioners for their supervisory function is not required under the CoPs. As to the requirement that the operating practitioner or anesthesiologist be "immediately available if needed" (and this requirement exists in both the Indiana Rules and the CoPs), the Interpretive Guidelines A for 42 C.F.R provide the following: "Immediately available" to intervene includes at a minimum, that the supervising anesthesiologist or operating practitioner, as applicable, is: physically located within the operative suite or in the labor and delivery unit; prepared to immediately conduct hands-on intervention if needed; and
4 not engaged in activities that could prevent the supervising practitioner from being able to immediately intervene and conduct hands-on interventions if needed. While the "immediate availability standard" is not hard to meet in the course of surgery, CRNAs who perform anesthesia services outside of the operating suite (the classic example being administration of epidurals), must provide for the required supervision by arranging for a designated physician to be immediately available, if needed. III. JCAHO Standards for Supervision of CRNAs. JCAHO Standard PC.13.20, EP11 requires that "before sedating or anesthetizing a patient, a "licensed independent practitioner' with appropriate clinical privileges plans or concurs with the planned anesthesia." Additionally, JCAHO Standard PC.13.40, EP4 requires that, "patients are discharged from the recovery area and the hospital by a qualified licensed independent practitioner or according to rigorously applied criteria approved by the clinical leaders." Finally, JCAHO Standard IM.6.30, EP6 requires that "postoperative documentation records the patient's discharge from the post-sedation or post-anesthesia care area by the responsible licensed independent practitioner or according to discharge criteria." A licensed independent practitioner ("LIP") is defined by JCAHO as:... any individual permitted by law and by the organization to provide care, treatment, and services without direction or supervision, within the scope of the individual's license and consistent with individually granted clinical privileges. There is some debate whether a CRNA constitutes an LIP under the JCAHO standards. It is arguable that a CRNA is not an LIP as that term is defined by JCAHO because the CRNA must be under the direction of the operating practitioner or a qualified physician/anesthesiologist under Indiana Rules and the CoPs. Under this interpretation, a CRNA could not serve as an LIP for purposes of meeting JCAHO Standards. The Rules and CoPs may also be interpreted to allow the independent practice of a CRNA, by virtue of the CRNA's ability to work outside of the immediate presence of a physician (while the physician still must be immediately available in an emergency). Although interpretations of JCAHO Standard PC.13.20, EP11 and the LIP definitions are subject to debate, particularly with respect to the language "direction" and "supervision", to date, we are not aware of any Indiana hospital having been involved in a JCAHO citation of Standard PC.13.20, EP11 based on improper CRNA credentialing or supervision. If this is not the case, IHHA General Counsel would appreciate hearing of any situations where a hospital has been cited for violation of the JCAHO anesthesia standards cited above.
5 IV. HFAP Standards: HFAP Standard , governing who may administer anesthesia, is identical to the Medicare CoP discussed above. V. Pre- and Post-Anesthesia Services. With regard to the Indiana Rules and the CoPs, both require that a pre-anesthesia evaluation by an individual qualified to administer anesthesia be performed within 48 hours prior to surgery. An intra-operative anesthesia record must be established for each patient. With respect to inpatients, a postanesthesia follow-up report must be written within 48 hours after surgery by the individual who administered the anesthesia. For each outpatient, a post-anesthesia evaluation documenting proper anesthesia recovery must be written in accordance with written policies and procedures approved by the medical staff. According to Captain Eddinger of CMS, under the CoPs, a preanesthesia evaluation by a CRNA must be reviewed and countersigned by the supervising practitioner. Likewise, the intraoperative anesthesia record and post-anesthesia evaluation or follow-up report (as the case may be) must be reviewed and countersigned by the supervising practitioner if completed by the CRNA unless the State obtains a Supervision Exemption through the office of the Governor. (see General Conclusion and Recommendations below). While Captain Eddinger concedes that the pre- and post-anesthesia services are of a less urgent nature and accordingly do not require the supervision of an anesthesiologist or operating practitioner who is immediately available, if needed, nevertheless, some lower level of supervision is required under the CoPs. This interpretation of Captain Eddinger (i.e., requiring a countersignature by a supervising physician) is different than previous advice provided by IHHA Legal Counsel in individual letters to certain IHHA members. Previously, it was the opinion of IHHA Counsel that such a countersignature was not required, given the very specific language present in the Rules. However, given Captain Eddinger's comments, and the HFAP accreditation standards, implementing a policy to have a countersignature by a supervising physician would be prudent. The HFAP standards specifically state, "[i]f the pre-anesthesia evaluation is performed by a non-physician, physician supervision shall be required" unless the State obtains a Supervision Exemption through the office of the Governor.. Further, "[i]f a non-physician performs the anesthesia service and completes the intra-operative record, supervision shall be required." Finally, the HFAP standards do not specifically address the supervision of CRNAs performing postanesthesia follow-up reports, but given Captain Eddinger's comments, supervision would be indicated. Conclusion and General Recommendations The supervision of CRNAs in Indiana hospitals poses regulatory,
6 operational, and accreditation challenges to hospital administration. In the absence of a physician or operating practitioner being always "immediately available", hospitals will have to be creative to assure that the CRNA supervision requirements are met. Outside of anesthesia provided in the operating suite where an operating practitioner is essentially always present, other arrangements for the required supervision may need to be considered. For example, an ED physician may need to come to the maternity unit during the administration of an epidural by a CRNA. In other instance, if a physician cannot go to the unit, the patient may need to be transported via gurney or wheelchair to the location of the ED physician or other supervising practitioner, when possible. This is an area where there is clearly some degree of confusion between the Indiana Rules, accrediting body standards, and the Medicare CoPs. It is critical that the CRNA and supervising practitioner document all required supervisory intervention in the medical record, especially in the situation where an ED Physician might be providing the required supervision. Written orders for the anesthesia services must also be documented in the record. As the old adage goes, "if it's not in the record, it didn't happen." If a number of Indiana hospitals are having difficulties meeting these requirements, they may want to consider discussing these issues with IHHA General Counsel to have the Governor address this issue pursuant to 42 CFR Section (c). This regulatory provision in the CoPs provides for a state supervision exemption. Under the exemption provision, the state may submit a letter to CMS signed by the Governor, following consultation with the state Boards of Medicine and Nursing, requesting exemption from supervision of CRNAs. The Governor must attest that he/she has consulted with the Boards about issues related to access to and quality of anesthesia services in the state and has concluded that it is in the best interests of the state's citizens to opt out of the physician supervision requirements and that the opt-out is consistent with state law. The request for exemption and recognition of state laws are effective upon submission of the Governor's request. IHHA General Counsel would be interested in hearing from Indiana hospitals regarding any current difficulties in complying with the CRNA supervision requirements, or accreditation standards. Any such comments may be submitted to the attorneys named below. Should you have any questions, please do not hesitate to contact your local counsel or Adele Merenstein or Timothy C. Lawson at Hall, Render, Killian, Heath & Lyman, P.C. at 317/ This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader must consult with legal counsel to determine how laws or decisions discussed herein apply to the reader's specific circumstances.
7 DOXBOX/190252_1.DOC
ANESTHESIA SERVICES (AS)
ANESTHESIA SERVICES (AS) AS.1 ORGANIZATION SR.1 Anesthesia services shall be provided in an organized manner, and function under the direction of a qualified doctor of medicine or osteopathy (or other
More informationCenter for Medicaid and State Operations/Survey and Certification Group
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard, Mail Stop S2-12-25 Baltimore, Maryland 21244-1850 Center for Medicaid and State Operations/Survey
More informationThere are four anesthesia categories as determined by CMS that affect payment of anesthesia services based on the provider rendering the services:
PROVIDER BILLING GUIDELINES Anesthesia Background Qualified medical professionals administer anesthesia to relieve pain while at the same time monitoring and controlling the patients health and vital bodily
More informationCALIFORNIA ASSOCIATION OF NURSE ANESTHETISTS CRNA SCOPE OF PRACTICE GUIDELINES
CALIFORNIA ASSOCIATION OF NURSE ANESTHETISTS CRNA SCOPE OF PRACTICE GUIDELINES The following offers guidance on the scope of practice for Certified Registered Nurse Anesthetists (CRNAs) in California.
More informationAmbulatory Surgery Center Ambulatory Surgical Center Conditions for Coverage Checklists Medicare Conditions for Coverage
Ambulatory Surgery Center Ambulatory Surgical Center Conditions for Coverage Checklists Medicare Conditions for Coverage, Esq. Garvey Schubert Barer 1191 Second Avenue, Suite 1800 Seattle, WA 98101 practices
More information36States Require Physician Supervision of Nurse Anesthetists
36States Require Physician Supervision of Nurse Anesthetists 34 states follow the federal requirement that physicians supervise nurse anesthetists. State law also requires physician supervision or direction
More informationSECTION 5 HOSPITAL SERVICES. Free-Standing Ambulatory Surgical Center
SECTION 5 HOSPITAL SERVICES Table of Contents 1 GENERAL POLICY... 2 1-1 Clients Enrolled in a Managed Care Plan... 3 1-2 Clients NOT Enrolled in a Managed Care Plan (Fee-for-Service Clients)..................
More information519.2 ANESTHESIA SERVICES. Background... 2. Policy... 2. 519.2.1 Covered Services... 2. 519.2.1.1 Anesthesiologist Directed Services...
TABLE OF CONTENTS SECTION PAGE NUMBER Background... 2 Policy... 2 519.2.1 Covered Services... 2 519.2.1.1 Anesthesiologist Directed Services... 3 519.2.1.2 Emergency Anesthesia... 4 519.2.1.3 Monitored
More information16 States With RN Supervision Language as it relates to Surgical Techs working in Hospitals Last Update 1/24/2013
16 States With Language as it relates to Surgical Techs working in Hospitals Last Update 1/24/2013 STATE CITATION STATUTORY LANGUAGE SUPERVISION OF ST LANGUAGE Alabama 420-5-7-.17 Surgical Services. Under
More informationComparison of Certified Registered Nurse Anesthetists (CRNAs) and Anesthesiologist Assistants (AAs)
Comparison of Certified Registered Nurse Anesthetists (CRNAs) and Anesthesiologist Assistants (AAs) CRNAs Definition: A CRNA is an advanced practice registered nurse specializing in nurse anesthesia. CRNAs
More informationTable of Contents A. General Billing Information.3 B. Reimbursement Guidelines...5 C. Documentation for Anesthesia Record...9
ANESTHESIA BILLING AND REIMBURSEMENT POLICY Payment policies apply to all in-network and out-of-network providers who render services to Neighborhood Health Plan of Rhode Island subscribers covered under
More informationAgency for Health Care Administration
Page 1 of 498 FED - A0000 - INITIAL COMMENTS Title INITIAL COMMENTS CFR Type Memo Tag FED - A0001 - NON-PARTICIPATING HOSPITALS, EMERGENCIES Title NON-PARTICIPATING HOSPITALS, EMERGENCIES CFR 482.2 Type
More informationHealth and Human Services Commission Council. SUBJECT: Item 5.a. Payment to Advanced Practice Registered Nurses and Physician Assistants
TO: Health and Human Services Commission Council DATE: August 15, 2014 FROM: Laurie Vanhoose, Medicaid/CHIP, Director of Policy Development SUBJECT: Item 5.a. Payment to Advanced Practice Registered Nurses
More informationScope and Standards for Nurse Anesthesia Practice
Scope and Standards for Nurse Anesthesia Practice Copyright 2010 222 South Prospect Ave. Park Ridge, IL 60068 www.aana.com Scope and Standards for Nurse Anesthesia Practice The AANA Scope and Standards
More informationRise in office-based surgery and anesthesia demands vigilance over safety Advances in technology and anesthesia allow invasive
ECRI Institute Perspectives Rise in office-based surgery and anesthesia demands vigilance over safety Advances in technology and anesthesia allow invasive procedures once done only in hospitals or ambulatory
More informationAMA founded in 1847. U.S. Medical care highly regulated. Medical Doctor? Scope of Practice in the United States
Scope of Practice in the United States AMA founded in 1847 World Health Professions Conference on Regulation Michael D. Maves, MD, MBA Chief Executive Officer and EVP American Medical Association February
More informationPHYSICAL PRESENCE REQUIREMENTS and DOCUMENTATION REQUIREMENTS (see Attachment I Acceptable Documentation Templates)
FACULTY PRACTICE PLAN TEACHING PHYSICIAN BILLING POLICY (Based on Medicare Carriers Manual Transmittal 1780, Section 15016, Supervising Physicians in Teaching Settings, Effective 11/22/2002) PURPOSE The
More informationScope and Standards for Nurse Anesthesia Practice
Scope and Standards for Nurse Anesthesia Practice Copyright 2013 222 South Prospect Ave. Park Ridge, IL 60068 www.aana.com Scope and Standards for Nurse Anesthesia Practice The AANA Scope and Standards
More informationAdvanced Practice Nurses Authority to Diagnose and Prescribe
Advanced Practice Nurses Authority to Diagnose and Prescribe ted ec ot. r p e ht ion th rig mat of ty y r y p s o cie Co inf rte So u l o a dc dic ide Me e t a St ois v ro P n Illi www.isms.org ADVANCED
More informationGuidelines for Core Clinical Privileges Certified Registered Nurse Anesthetists
Guidelines for Core Clinical Privileges Certified Registered Nurse Anesthetists Copyright 2005 222 South Prospect Park Ridge, IL 60068 www.aana.com Guidelines for Core Clinical Privileges Certified Registered
More informationBEFORE THE ALABAMA BOARD OF NURSING IN THE MATTER OF: ) PETITION FOR ) DECLARATORY RULING STEVE SYKES, M.D., ) ) ) Petitioner. ) DECLARATORY RULING
BEFORE THE ALABAMA BOARD OF NURSING IN THE MATTER OF: ) PETITION FOR ) DECLARATORY RULING STEVE SYKES, M.D., ) ) ) Petitioner. ) DECLARATORY RULING COMES NOW the Alabama Board of Nursing, by and through
More informationTitle 30: Professions and Occupations. Part 2630 Collaboration. Part 2630 Chapter 1: Collaboration with Nurse Practitioners
Title 30: Professions and Occupations Part 2630 Collaboration Part 2630 Chapter 1: Collaboration with Nurse Practitioners Rule 1.1 Scope. These rules apply to all individuals licensed to practice medicine
More informationHealthcare Inspection. Supervision of Nurse Anesthetists in the Anesthesia Section Dayton VA Medical Center Dayton, Ohio
Department of Veterans Affairs Office of Inspector General Healthcare Inspection Supervision of Nurse Anesthetists in the Anesthesia Section Dayton VA Medical Center Dayton, Ohio Report No. 12-01431-223
More informationCenter for Medicaid and State Operations/Survey and Certification Group
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard, Mail Stop S2-12-25 Baltimore, Maryland 21244-1850 Center for Medicaid and State Operations/Survey
More informationCenter for Medicaid and State Operations/Survey & Certification Group
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard, Mail Stop S2-12-25 Baltimore, Maryland 21244-1850 Center for Medicaid and State Operations/Survey
More informationMEDICAL STAFF RULES AND REGULATIONS
MEDICAL STAFF RULES AND REGULATIONS ARTICLE I. PROFESSIONALISM 1.1 These rules and regulations are intended to provide comprehensive information to members of the Ambulatory Surgery Center in order for
More informationIn the Hospital Setting
In the Hospital Setting 2013 PENNSYLVANIA HOSPITAL QUALITY: Achieving More Together Use of Physician Assistants, Certified Registered Nurse Practitioners, Certified Nurse Midwives, Certified Registered
More informationOhio Legislative Service Commission
Ohio Legislative Service Commission Bill Analysis Lisa Musielewicz S.B. 228 129th General Assembly (As Introduced) Sens. Burke, Lehner, Schiavoni, Tavares, Schaffer BILL SUMMARY Authorizes a certified
More informationProfessional Liability Insurance. Application. (For Professional Corporations or Other Legal Entities)
Professional Liability Insurance Application (For Professional Corporations or Other Legal Entities) Application for Professional Liability Insurance (For Professional Corporations or Other Legal Entities)
More informationMedicare Information for Advanced Practice Nurses and Physician Assistants. September 2010 / ICN: 901623
R Medicare Information for Advanced Practice Nurses and Physician Assistants September 2010 / ICN: 901623 This publication provides information about required qualifications, coverage criteria, billing,
More informationInterdisciplinary Admission Assessment and
06/20/14 - Effective Definitions Policy Licensed Independent Practioner (LIP): Any individual permitted by law and UTMB to provide care and services without direction or supervision within the scope of
More informationStatus Active. Reimbursement Policy Section: Anesthesia Services Policy Number: RP - Anesthesia - 001 Anesthesia Effective Date: June 1, 2015
Status Active Reimbursement Policy Section: Anesthesia Services Policy Number: RP - Anesthesia - 001 Anesthesia Effective Date: June 1, 2015 Anesthesia Policy Description: Definitions: This policy addresses
More informationHANDBOOK FOR ADVANCED PRACTICE NURSES
HANDBOOK FOR ADVANCED PRACTICE NURSES CHAPTER N 200 Policy and Procedures for Advanced Practice Nurse Services Illinois Department of Public Aid FOREWORD PURPOSE CHAPTER N-200 ADVANCED PRACTICE NURSE SERVICES
More informationCh. 551 GENERAL INFORMATION 28. Subpart F. AMBULATORY SURGICAL FACILITIES
Ch. 551 GENERAL INFORMATION 28 Subpart F. AMBULATORY SURGICAL FACILITIES Chap. Sec. 551. GENERAL INFORMATION...551.1 553. OWNERSHIP, GOVERNANCE AND MANAGEMENT... 553.1 555. MEDICAL STAFF...555.1 557. QUALITY
More informationProgram of Anesthesia Madisonville, Kentucky Orientation 2013
Program of Anesthesia Madisonville, Kentucky Orientation 2013 Contact Information: BH/MSU School of Anesthesia: Email: Anesprog@trover.org Phone: 270-824-3460 A Little History Anesthetics have been administered
More informationWHAT YOU NEED TO KNOW. Jay Mesrobian, M.D. John Stephenson, M.D. David Biel, AA C Michael Nichols, AA C
INTEGRATING ANESTHESIOLOGIST ASSISTANTS INTO YOUR PRACTICE: WHAT YOU NEED TO KNOW Jay Mesrobian, M.D. John Stephenson, M.D. David Biel, AA C Michael Nichols, AA C I Introduction Incorporation of Anesthesiologist
More informationCertified Registered Nurse Anesthetist Arizona Legislative History
Certified Registered Nurse Anesthetists Arizona Legislative history On March 10, 1923 Governor George W. P. Hunt signed House Bill 146. The new law stated, That all regularly graduated and registered nurses
More informationElectronic Health Record License Agreements
Presenting a live 90-minute webinar with interactive Q&A Electronic Health Record License Agreements Negotiating Scope of License, Warranties and Liability Disclaimers and Other Key Provisions THURSDAY,
More informationAnesthesia Services INDIANA HEALTH COVERAGE PROGRAMS. Copyright 2016 Hewlett Packard Enterprise Development LP
INDIANA HEALTH COVERAGE PROGRAMS PROVIDER REFERENCE M ODULE Anesthesia Services L I B R A R Y R E F E R E N C E N U M B E R : P R O M O D 0 0 0 1 9 P U B L I S H E D : F E B R U A R Y 25, 2 0 1 6 P O L
More informationDepartment of Anesthesiology (Jax) College of Medicine Jacksonville Anesthesiology Billing Compliance Plan Revised October 1, 2015
Department of Anesthesiology (Jax) College of Medicine Jacksonville Anesthesiology Billing Compliance Plan Revised October 1, 2015 I. Billing Compliance Administrative Policies and Procedures 1.0 INTRODUCTION
More informationBilling & Compliance for Anesthesia Services. Charles Whitten, MD Professor and Chairman
Billing & Compliance for Anesthesia Services Charles Whitten, MD Professor and Chairman Anesthesia Billing Anesthesia is a Unique Specialty ASA* vs. CPT codes Anesthesia Specific Modifiers Time based Billing
More informationSTATEMENT COMPARING ANESTHESIOLOGIST ASSISTANT AND NURSE ANESTHETIST EDUCATION AND PRACTICE
Committee of Origin: Anesthesia Care Team (Approved by the ASA House of Delegates on October 17, 2007, and last amended on October 17, 2012) Anesthesiologist Assistants (AA) and nurse anesthetists are
More informationTeaching Physician Billing Compliance. Effective Date: March 27, 2012. Office of Origin: UCSF Clinical Enterprise Compliance Program. I.
Teaching Physician Billing Compliance Effective Date: March 27, 2012 Office of Origin: UCSF Clinical Enterprise Compliance Program I. Purpose These Policies and Procedures are intended to clarify the Medicare
More informationAnesthesia Guidelines
Anesthesia Guidelines Updated April 2012 Anesthesia BlueCross requires anesthesiologists and certified registered nurse anesthetists (CRNAs) to file claims using CPT anesthesia codes. We cover general
More informationWhy would we want to change a practice with a track record that has proven safe and that works well?
Good morning, Mr. Chairman and distinguished members of the House Professional Licensure Committee. My name is Dr. Erin Sullivan. I am president of the Pennsylvania Society of Anesthesiologists and a board
More informationREGISTERED NURSE AS CIRCULATOR FOR ASC Last updated 5/16/2012
REGISTERED NURSE AS CIRCULATOR FOR ASC Last updated 5/16/2012 STATE CITATION STATUTORY / REGULATORY LANGUAGE Alabama ALABAMA ADMINISTRATIVE 420-5-2-.02 Administration (3) Personnel... (b) Director of Nursing
More information2013 -- S 0197 S T A T E O F R H O D E I S L A N D
======= LC00 ======= 01 -- S 01 S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO BUSINESSES AND PROFESSIONS - NURSES AND NURSE ANESTHETISTS Introduced
More informationIntroduction to Perioperative Nursing
Jones & Bartlett Learning, LLC. NOT FOR SALE OR DISTRIBUTION C H A P T E R 1 Introduction to Perioperative Nursing Learner Objectives 1. Define the three phases of the surgical experience. 2. Describe
More informationHow To Get A Hospital Stay For A Year
2-Midnight Rule: Implications for Auditor Behavior and Appeal Strategies Jessica L. Gustafson, Esq. The Health Law Partners, P.C. 29566 Northwestern Hwy., Ste. 200 Southfield, MI 48236 www.thehlp.com 1
More informationDQA Hospital Q&A Page 1 of 24 Created on 03/10/2010 1:15:00 PM
DQA Hospital Q&A Page 1 of 24 Created on 03/10/2010 1:15:00 PM 1. Is there a specific regulation or an interpretation of a regulation, in which soiled utility room doors must be locked? No. There is not
More informationThe facility must have methods in place to ensure staff are managed effectively to support the care, treatment and services it provides.
HUMAN RESOURCES The facility must have methods in place to ensure staff are managed effectively to support the care, treatment and services it provides. This standard addresses human resource planning,
More informationAnesthesia Billing: 101. Presented by: Medi-Corp, Inc www.medi-corp.com
Anesthesia Billing: 101 Presented by: Medi-Corp, Inc www.medi-corp.com Disclaimer Statement The material enclosed is based on information that is in effect at the time of this presentation. This presentation
More informationThe ASA defines anesthesiology as the practice of medicine dealing with but not limited to:
1570 Midway Pl. Menasha, WI 54952 920-720-1300 Procedure 1205- Anesthesia Lines of Business: All Purpose: This guideline describes Network Health s reimbursement of anesthesia services. Procedure: Anesthesia
More informationWhat You Need to Know About Anesthesia Filing Guidelines
What You Need to Know About Anesthesia Filing Guidelines 2015 Edition Published by Provider Relations and Education Your Partners in Outstanding Quality, Satisfaction and Service This document provides
More informationPrescriptive Authority FAQ: Washington CRNAs
: Washington CRNAs This FAQ (Frequently Asked Questions) is maintained by. If you have comments or a question that is not answered here, please send it to wana1@comcast.net. DISCLAIMER: Please remember,
More information2/20/2014. Joette Derricks, CPC, CHC, CMPE, CSSGB, CLHC Vice-President, Regulatory Affairs & Research Anesthesia Business Consultants
Joette Derricks, CPC, CHC, CMPE, CSSGB, CLHC Vice-President, Regulatory Affairs & Research Anesthesia Business Consultants Neda M. Ryan, Attorney, Clark Hill PLC Anesthesia Business Consultants, Clark
More information100.1 - Payment for Physician Services in Teaching Settings Under the MPFS. 100.1.1 - Evaluation and Management (E/M) Services
MEDICARE CLAIMS PROCESSING MANUAL Accessed September 25, 2005 100.1 - Payment for Physician Services in Teaching Settings Under the MPFS Payment is made for physician services furnished in teaching settings
More informationCMS-1590-P 228. We believe that the behavioral therapy service described by HCPCS code G0446 requires
CMS-1590-P 228 We believe that the behavioral therapy service described by HCPCS code G0446 requires similar physician work to CPT code 97803 (work RVU = 0.45) and should be valued similarly. As such,
More informationCredentialing Telemedicine Providers
BUSINESS ATTORNEYS FOR BUSINESS SUCCESS Credentialing Telemedicine Providers Provider Credentialing requirements raise important considerations in any telemedicine arrangement. The facility where care
More information1) ELIGIBLE DISCIPLINES
PRACTITIONER S APPLICABLE TO ALL INDIVIDUAL NETWORK PARTICIPANTS AND APPLICANTS FOR THE PREFERRED PAYMENT PLAN NETWORK, MEDI-PAK ADVANTAGE PFFS NETWORK AND MEDI-PAK ADVANTAGE LPPO NETWORK. 1) ELIGIBLE
More informationPrerequisites. Authorization, Notification and Referral. Limitations ANESTHESIA SERVICES
ANESTHESIA SERVICES Policy NHP reimburses participating providers for the administration of general and regional anesthesia, and supportive services performed in conjunction with covered obstetrical, surgical,
More informationCertified RN anesthetist
Practice area 170 Clinical PRIVILEGE WHITE PAPER Certified RN anesthetist Background A certified RN anesthetist (CRNA) is an advanced practice RN who provides anesthesia to patients in collaboration with
More informationINS AND OUTS OF MID-LEVEL PROVIDER BILLING
INS AND OUTS OF MID-LEVEL PROVIDER BILLING Presented by: Amy E. Bishard, BA, CPC, CPMA, CEMC, RCC OBJECTIVES Describe scopes of practice for Nurse Practitioners and Physician Assistants Discuss documentation
More informationAnesthesia Services Effective 12/1/06
EqualityCareNews October 2006 Coverage ATTENTION PROVIDERS Anesthesia Services Effective 12/1/06 CMS-1500 Bulletin 06-009 EqualityCare covers anesthesia only when administered by a licensed anesthesiologist
More informationBOARD OF DENTAL EXAMINERS Professional & Vocational Licensing Division Department of Commerce and Consumer Affairs State of Hawaii
BOARD OF DENTAL EXAMINERS Professional & Vocational Licensing Division Department of Commerce and Consumer Affairs State of Hawaii MINUTES OF COMMITTEE MEETINGS Rules Committee The agenda for this meeting
More informationDream a Little Dream: A Certified Registered Nurse Anesthetist Is By Your Side. Sierra Gower, CRNA, MS
Dream a Little Dream: A Certified Registered Nurse Anesthetist Is By Your Side Sierra Gower, CRNA, MS Anesthesia in the United States In the USA anesthesia care is provided by three specialty groups, nurse
More informationSHORT TITLE: Professions and occupations; certified registered nurse anesthetist scope of practice; effective date.
SHORT TITLE: Professions and occupations; certified registered nurse anesthetist scope of practice; effective date. STATE OF OKLAHOMA 2nd Session of the 45th Legislature (1996) SENATE BILL NO. 943 By:
More informationCLINICAL PRIVILEGES- NURSE ANESTHETIST
Name: Page 1 Initial Appointment Reappointment All new applicants must meet the following requirements as approved by the governing body effective: 8/5/2015. Applicant: Check off the Requested box for
More informationCHAPTER 152 SENATE BILL 1362 AN ACT
Senate Engrossed State of Arizona Senate Fiftieth Legislature Second Regular Session 0 CHAPTER SENATE BILL AN ACT AMENDING SECTION -0, ARIZONA REVISED STATUTES; AMENDING TITLE, CHAPTER, ARTICLE, ARIZONA
More informationHOSPICE UTILIZATION OF NURSE PRACTITIONERS. July, 2006
H O S P I C E A N D P A L L I A T I V E C A R E P R A C T I C E G R O U P HOSPICE AND PALLIATIVE CARE PRACTICE GROUP: Mary H. Michal, Chair Linda Dawson Meg S. L. Pekarske Matthew K. McManus 22 East Mifflin
More informationIWCC 50 ILLINOIS ADMINISTRATIVE CODE 7110 7110.90. Section 7110.90 Illinois Workers' Compensation Commission Medical Fee Schedule
Section 7110.90 Illinois Workers' Compensation Commission Medical Fee Schedule a) In accordance with Sections 8(a), 8.2 and 16 of the Workers' Compensation Act [820 ILCS 305/8(a), 8.2 and 16] (the Act),
More informationOverview of Outpatient Care Settings and Ambulatory Surgery Centers
Overview of Outpatient Care Settings and Ambulatory Surgery Centers Agency for Health Care Administration Molly McKinstry, Deputy Secretary Health Quality Assurance Surgical Settings Ambulatory Surgery
More informationHCCA Quality of Care Compliance Conference. Quality of Care Conference
HCCA Quality of Care Compliance Conference October 11-13, 2009 Philadelphia, PA 1 Quality of Care Conference MEDICARE CONDITIONS OF PARTICIPATION, QUALITY, and SCOPE OF PRACTICE John E. Steiner, Jr., Esq,
More informationThe Scope of Practice of Nurse Anesthetists
The Scope of Practice of Nurse Anesthetists American Society of Anesthesiologists January 2004 Table of Contents Preface.................................................................................
More informationVIRGINIA DEPARTMENT OF HEALTH PROFESSIONS
Commonwealth of Virginia VIRGINIA DEPARTMENT OF HEALTH PROFESSIONS REGULATIONS GOVERNING THE PRACTICE OF PHYSICAL THERAPY Title of Regulations: 18 VAC 112-20-10 et seq. Statutory Authority: Chapter 34.1
More informationLOUISIANA STATE UNIVERSITY HEALTH SCIENCES CENTER - SHREVEPORT MEDICAL RECORDS CONTENT/DOCUMENTATION
LOUISIANA STATE UNIVERSITY HEALTH SCIENCES CENTER - SHREVEPORT MEDICAL RECORDS CONTENT/DOCUMENTATION Hospital Policy Manual Purpose: To define the components of the paper and electronic medical record
More informationPOLICY No. 20-049. Prepared by: Judith Kell Effective: December 20, 2002 Compliance Review Supervisor Revised: January 23, 2009
LAKESHORE BEHAVIORAL HEALTH ALLIANCE Community Mental Health Services of Muskegon County Community Mental Health of Ottawa County Lakeshore Coordinating Council for Substance Abuse Services POLICY Prepared
More informationRegions Hospital Delineation of Privileges Certified Registered Nurse Anesthetist
Regions Hospital Delineation of Privileges Certified Registered Nurse Anesthetist Applicant s Name: Last First M. Instructions: Place a check-mark where indicated for each core group you are requesting.
More informationModerate sedation. Procedure 34. Background
Procedure 34 Clinical PRIVILEGE WHITE PAPER Moderate sedation Background According to The Joint Commission and the American Society of Anesthesiologists (ASA), moderate sedation (sometimes referred to
More information2008 SUMMARY OF STATE ACTIVITIES 1 Prepared by Lisa Percy Albany, J.D. Manager, ASA State Legislative & Regulatory Issues.
2008 SUMMARY OF STATE ACTIVITIES 1 Prepared by Lisa Percy Albany, J.D. Manager, ASA State Legislative & Regulatory Issues OPT-OUTs To date, the last opt-out was three years ago. Fourteen states have opted
More informationr JOHNS HOPKINS HEALTHCARE Physician Guidelines Subject: Anesthesia Processing Guidelines Lines of Business: EHP, USFHP, Priority Partners
Revision Date: 11/14/14 Last Reviewed Date: 11/14/14 Page 1 of 7 ACTION New Procedure Amending Procedure Number: Superseding Procedure Number: Repealing Procedure Number: REFERENCES: AMPT Committee ASA
More informationTHE ORGANIZATION OF AN ANESTHESIA DEPARTMENT
THE ORGANIZATION OF AN ANESTHESIA DEPARTMENT Committee of Origin: Quality Management and Departmental Administration (Approved by the ASA House of Delegates on October 15, 2003, and last amended on October
More informationCOMMUNITY HEALTH NETWORK ALLIED HEALTH PROFESSIONAL POLICY MANUAL
COMMUNITY HEALTH NETWORK ALLIED HEALTH PROFESSIONAL POLICY MANUAL OBJECTIVE: To establish the method by which Allied Health Professionals may be granted clinical privileges and appointment to the Allied
More informationSection 1300.EXHIBIT A Sample Written Collaborative Agreement ADVANCED PRACTICE NURSING WRITTEN COLLABORATIVE AGREEMENT
TITLE 68: PROFESSIONS AND OCCUPATIONS CHAPTER VII: DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION SUBCHAPTER b: PROFESSIONS AND OCCUPATIONS PART 1300 NURSE PRACTICE ACT SECTION 1300.EXHIBIT A SAMPLE
More informationCredentials Policy Manual. Reviewed & Approved by MEC 8/13/2012 Reviewed & Approved by Board of Commissioners 9/11/12
Credentials Policy Manual Reviewed & Approved by MEC 8/13/2012 Reviewed & Approved by Board of Commissioners 9/11/12 Credentialing Policy Manual Table of Contents I. Application for Appointment to Staff...1
More informationProvider restrictions apply please see Behavioral Health Policy.
Payment Policy Mid-Level Practitioner EFFECTIVE DATE: 02 02 2006 POLICY LAST UPDATED: 10 01 2013 OVERVIEW This policy documents the services covered when rendered by a BCBSRI credentialed Mid-level practitioners
More informationHOUSE OF REPRESENTATIVES STAFF ANALYSIS
HOUSE OF REPRESENTATIVES STAFF ANALYSIS BILL #: HB 187 Health Insurance--Certified Surgical First Assistants SPONSOR(S): Homan TIED BILLS: IDEN./SIM. BILLS: SB 594 REFERENCE ACTION ANALYST STAFF DIRECTOR
More informationRevised July 2014 MEDICAL STAFF BYLAWS OF MINISTRY OUR LADY OF VICTORY HOSPITAL, INC.
MEDICAL STAFF BYLAWS OF MINISTRY OUR LADY OF VICTORY HOSPITAL, INC. DEFINITIONS 1. MEDICAL STAFF means all Doctors of Medicine, Doctors of Osteopathy, Doctors of Dentistry and Doctors of Podiatry, who
More informationPOLICIES AND PROCEDURES GOVERNING ANESTHESIA PRIVILEGING IN HOSPITALS
POLICIES AND PROCEDURES GOVERNING ANESTHESIA PRIVILEGING IN HOSPITALS **Hospitals must review and revise with legal counsel and ensure compliance with State and federal laws and regulations. ASA intends
More informationPlease consider including National Nurse Anesthetists Week in your community calendar.
January 8, 2014 Dear or Editor/News Director: Minnesota s nurse anesthetists will be joining their colleagues across the country to celebrate the 15th annual National Nurse Anesthetists Week, Jan. 19-25.
More informationTable of Contents Forward... 1 Introduction... 2 Evaluation and Management Services... 3 Psychiatric Services... 6 Diagnostic Surgery and Surgery...
Table of Contents Forward... 1 Introduction... 2 Evaluation and Management Services... 3 Psychiatric Services... 6 Diagnostic Surgery and Surgery... 6 Other Complex or High Risk Procedures... 7 Radiology,
More informationAllied Health Care Provider: Appointment and Re-appointment
Allied Health Care Provider: Appointment and Re-appointment Document Owner: Lawson, Louise Version: 8 Effective Date: 10/23/2013 Revision Date: 4/26/2015 Approvers: Calkins, Paul; Del Boccio, Suzanne;
More informationAdvanced Practice Registered Nurse Legislation
Minnesota Nurses Association Advanced Practice Registered Nurse Legislation Minnesota Nurses Association Revised September, 2005 1625 Energy Park Drive, Suite 200 St. Paul, MN 55108 Phone: (651) 646-4807
More informationGuidelines for the Management of the Obstetrical Patient for the Certified Registered Nurse Anesthetist
American Association of Nurse Anesthetists 222 South Prospect Avenue Park Ridge, IL 60068 www.aana.com Guidelines for the Management of the Obstetrical Patient for the Certified Registered Nurse Anesthetist
More informationProfessional Fee Billing Policy Policy 9100 PREFACE
POLICIES AND PROCEDURES FOR TEACHING PHYSICIAN BILLING COMPLIANCE PREFACE This document expands upon the interim guidelines implemented at UCLA effective July 1, 1996. These Policy and Procedures are intended
More informationPhysician Assistant Licensing Act
45:9-27.10. Short title 1. This act shall be known and may be cited as the "Physician Assistant Licensing Act." L.1991,c.378,s.1. 45:9-27.11. Definitions 2. As used in this act: "Approved program" means
More informationHealthcare Inspection. Evaluation of Management of Moderate Sedation in Veterans Health Administration Facilities
Department of Veterans Affairs Office of Inspector General Healthcare Inspection Evaluation of Management of Moderate Sedation in Veterans Health Administration Facilities Report No. 04-00330-15 November
More informationProvider-Based: What Is It?
Compliance Risks for Provider-Based and Other Hospital-Based Provider Services 2015 HCCA Compliance Institute Presented by Regan E. Tankersley, Esq. Hall, Render, Killian, Heath & Lyman, P.C. Paul W. Kim,
More informationINTRODUCTION. The Workers Compensation Act provides in part as follows:
INTRODUCTION The Maryland Workers Compensation Commission (Commission) amended COMAR 14.09.03.01 (Guide of Medical and Surgical Fees) on February 12, 2004. AUTHORITY The Workers Compensation Act provides
More informationCheck List. Telehealth Credentialing and Privileging Sec. 482.22. Conditions of Participation Medical Staff
Check List Telehealth Credentialing and Privileging Sec. 482.22. Conditions of Participation Medical Staff The Centers for Medicare and Medicaid Services (CMS) final rule on credentialing and privileging
More information