Region D RAC Reverses Anesthesia Care Package E&M Services Automated Review After Consultation With ASA

After a conference call and several requests for information, Health Data Insights, the Recovery Audit Contractor for Region D (Alaska, Arizona, California, Hawaii, Iowa, Idaho, Kansas, Missouri, Montana, North Dakota, Nebraska, Nevada, Oregon, South Dakota, Utah, Washington and Wyoming), has revised its decision to perform an automated review of anesthesia care package E&M services, according to a statement from the American Society of Anesthesiologists.

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ASA voiced its concerns that an automated review process could not differentiate when providers inappropriately separately reported typical pre- or post-anesthesia work covered by the base unit value assigned to an anesthesia code and when the codes reported an appropriately reported E&M services for post-op pain follow-up, according to the statement.

After speaking with ASA and consulting with the Centers for Medicare & Medicaid Services, HDI sent ASA the following revisions to its review:

  1. Automated review will continue to identify improper payments for E&M Services rendered the day of Anesthesia Services (CPT codes 00100 to 01999).
  2. Findings will include services rendered by the same individual Practitioner as well as services rendered by another member of the same group practice (based on Tax ID#) and of the same provider specialty.
  3. Automated review for E&M services not rendered on the day of Anesthesia Services (i.e., pre-op and post-op days) were discontinued on March 6, 2010. Consideration of Complex Review audits for pre- and post-operative day anesthesia services will be considered based on additional analysis of the Region D CMS Claims Data and workload priorities.
  4. Accordingly, the preoperative and postoperative day E&M lines submitted by HDI to Claims Processing Contractors for adjustment under this New Issue are being reversed. Any adjustments made by the CPC for services other than those pre-op and post-op day E&M services should be addressed with the CPC.

Read the ASA’s statement on HDI’s changes to its anesthesia services review (pdf).

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