CRNA Exemption

It’s that time of year for facilities to fill out the needed information to retain their exemption to the Certified Registered Nurse Anesthetist (CRNA) Fee Schedule and remain cost reimbursed. Be sure to meet the deadline mentioned in your letter and retain proof the documentation was sent in on or before the December 31st deadline.

Under the provisions at 42 CFR 412.113(c), “Payment is determined on a reasonable cost basis for anesthesia services provided in the hospital or CAH by qualified nonphysician anesthetists (certified registered nurse anesthetists and anesthesiologist’s assistants) employed by the hospital or CAH or obtained under arrangements”. It is the CAH’s responsibility to supply all supporting documentation to determine if the qualifications are met.

Qualifications:

1. Employ or contract with a qualified nonphysician anesthetist(s) to perform services in that hospital/CAH that does not exceed one FTE per year.
2. The volume of surgical procedures with anesthesia services does not exceed 800 procedures.
3. In writing, each qualified nonphysician anesthetist has agreed not to bill on a fee schedule basis for the patient care to Medicare beneficiaries.

If the MAC completes an audit of the nonphysician anesthetist reimbursement and the hospital has not met the requirements during the cost reporting period, the MAC will adjust out any costs, charges, and Medicare charges related to CRNA services, disallowing all cost reimbursement for CRNA services in that period.

Examples of CRNA documentation that may need to be submitted include copies of CRNA contracts, documentation of total hours worked at the hospital, a log of all surgical procedures performed during the specified time period, and a signed agreement by each CRNA not to bill on a fee schedule basis for patient care.

Also, if your facility qualifies for the CRNA exemption services, These charges are submitted on the UB-04 using revenue code 964 and the appropriate CPT code for the service rendered.