(Editor’s note: In this second part of a two-part series on anesthesia coding billing problems, we discuss pain management billing risks. In last month’s issue, we discussed steps to ensure you avoid fraudulent billing.)
While there are several areas within Medicare rules for anesthesia billing that are open to interpretation, treatment of pain management patients often presents the greatest risk for billing errors, says Karin Bierstein, JD, assistant director of governmental affairs for the Park Ridge, IL-based American Society of Anesthesiologists.
One common mistake is billing for medical direction at the same time a procedure, such as a nerve block, is performed personally by the anesthesiologist, she says. "The only times anesthesiologists can bill for services they provide at the same time they bill for medical direction are explained in the Medicare Carrier Manual," Bierstein points out.
These six activities are:
- receiving patients entering the operating suite for the next surgery;
- checking or discharging patients in the recovery room;
- handling scheduling matters;
- addressing an emergency of short duration in the immediate area;
- administering a labor epidural;
- periodically monitoring an obstetrics patient.
Know the proper coding
Improper use of evaluation and management codes in billing also is another area in which physicians err, Bierstein says. "An anesthesiologist may consider it an insult to their professionalism to say that they conduct less than a comprehensive evaluation on any patient, but when billing, there are definitions for a comprehensive evaluation," she explains.
It’s important to understand the different levels of office visits and the appropriate use of codes for them, she says. (Editor’s note: To access a list of the varying levels of service for evaluation and management codes typically used in a pain medicine practice, go to www.same-daysurgery.com. Click on "toolbox." The tool is listed under "anesthesia." You’ll need your subscriber number from your mailing label, because it is your user name. Your password is your subscriber number preceded by sds.)
You also cannot bill evaluation and management codes for established patients when a procedure is performed, says Bierstein. A history and physical for a scheduled procedure does not normally qualify for a separate billing charge, she explains. Anesthesiologists who perform their pain management procedures in a hospital or surgery center setting cannot bill as a "freestanding office," Bierstein says.
Even if the physician has an office in the hospital or surgery center, if the anesthesiologist is not paying for the supplies, drugs, and overhead costs related to the procedure, the physician cannot claim the facility fee, she says. It can be claimed only by the hospital or surgery center, Bierstein says. Another risky area for pain management treatment is failure to document the surgeon’s request for acute postoperative pain management, she adds. Routine postoperative pain control already is included in the surgeon’s global fee, so the anesthesiologist must document that the surgeon transferred care of the patient for the purpose of pain management, she says.
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