Cost Report Corner

Certified Registered Nurse Anesthetist (CRNA)

Have you ever heard the saying “The devil is in the details”? Well, in the case of CRNA services provided by a critical access hospital (CAH), you’d be correct.

Annually, CAHs must ensure that they meet the CMS criteria for cost-based reimbursement, submitting the appropriate data to their Medicare Administrative Contractor (MAC) in a timely fashion. This yearly exercise of submitting annualized procedure data to the MAC and attesting to the various CRNA qualification criteria may seem mundane to do every year – and that may be the case. However, if you ever miss a year of filing the appropriate paperwork AND/OR receiving the MAC approval letter, you will never forget this mundane task again. The reimbursement differential of having to bill all CRNA services on a CMS-1500 with fee schedule reimbursement versus UB billing with cost reimbursement for an entire calendar year will sharpen your memory and focus.

Do not procrastinate

When you receive the CRNA letter from your MAC, analyze, complete, review and submit the information in a timely fashion and ensure you receive the approval letter from the MAC. File this letter appropriately in your facility and provide a copy to your cost report preparer, so that you have the documentation should the need arise.

Questions you should ask yourself

If your CAH contracts for CRNA services, have you reviewed the contract lately with your cost report preparer? Are there provisions in your negotiated CRNA contract that unknowingly impact reimbursement? Have you received multiple bids for your CRNA contract to demonstrate you comply with the CMS prudent buyer principle? One of CMS’ current focus areas is to ensure the prudent buyer principle is being followed and can be verified.

At the time (and that time is now), all of these activities may seem mundane and unnecessary, but you will be glad you did when you get that “star” on your cost report during the MAC audit and ensure your facility receives correct reimbursement for CRNA services.