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Find clarity on how teaching anesthesiologists should be paid.

Whoever said knowledge is power perhaps should have specified that accurate or true knowledge is power. Misinformation, or 鈥渁lternative facts,鈥� are rampant. It is difficult to believe that anyone would share information that isn鈥檛 accurate or fact-based, but it may happen. Whether intentional or unintentional, one has to apply an idiom often repeated: 鈥淟earn to separate the wheat from the chaff.鈥�

To help anesthesia coders have a better understanding of anesthesia services in a teaching facility, knowing the background and where coders can find supporting resources is helpful.

Keep reading for more information on how the anesthesia specialty has faced reimbursement battles.

Understand the Background

Prior to both 2004 and 2010, teaching anesthesiologists were unfairly penalized for teaching residents and anesthesia was the only specialty financially penalized for teaching resident anesthesiologists. During these time periods, only 50 percent of the allowed amounts were paid for teaching two anesthesia residents, and the allowed amount was based on the documented amount of time spent in each case. Other specialties were not affected by this reduction in payment in a teaching facility.

You may have heard that anesthesiologists only receive full payment if they are overseeing a single case with a single resident, or you may have heard that a teaching anesthesiologist will only receive half of the expected payment from Medicare if they are medically directing between two and four cases involving residents or certified registered nurse anesthetists (CRNAs). That is no longer true.

Teaching guidelines were last updated in November 2024 Medicare Learning Network (MLN) publication MLN 006347, which confirmed the number of cases is limited to two concurrent anesthesia cases involving residents. However, these guidelines are an updated version of the changes that were made more than 15 years ago.

Pursuant to the U.S. Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) , dated Nov. 20, 2009: 鈥淓ffective for services furnished on or after Jan. 1, 2010, payment may be made under Section 139 of MIPPA based on the regular fee schedule amount for the teaching anesthesiologist鈥檚 involvement in the training of residents in either a single anesthesia case or two concurrent anesthesia cases. We are also applying this same policy if the teaching anesthesiologist is involved in one resident case that is concurrent to another case that is paid under the medical direction payment rules. However, the medical direction payment policy would apply to the concurrent case involving the certified registered nurse anesthetist (CRNA), anesthesiologist assistant (AA) or student nurse anesthetist.鈥�

See How Misinformation Was Perpetuated

If one has access to meetings, anesthesia industry alerts, or keeps up to date with information provided by the American Society of Anesthesiologists (ASA), numerous articles and resources supported this information. Unfortunately, if one does not have access to or has been told differently, misinformation may have been provided or followed. It would be a financial loss and detrimental to your practice if the old guidance was not updated.

Until 2004, CMS rules limited the physicians reported time units to the actual time spent in each of the two cases. After 2010, the CMS rule did not include the same language and allowed full base plus time to be billed for each case with a resident using AA GC modifiers. As indicated in the Oct. 19, 2020, Anesthesia Industry, 鈥渢he teaching anesthesiologist has gradually gained greater reimbursement when involved in two resident cases鈥�; although in this situation, the phrase 鈥済reater payment鈥� may be preferable to 鈥済reater reimbursement.鈥�

To further support the updated information, ASA published a on Nov. 9, 2009, providing scenarios to explain how anesthesia practices would be impacted by the approved changes as follows:

鈥淭he teaching anesthesiologist receives 100% of the fee schedule amount for the following cases:

• 鈥淭he teaching anesthesiologist is involved in one resident physician case (which is not concurrent to any other anesthesia case);
• 鈥淭he teaching anesthesiologist is involved in each of two concurrent resident cases (which are not concurrent to any other anesthesia case); or
• 鈥淭he teaching anesthesiologist is involved in one resident physician case that is concurrent to another case paid under medical direction payment rules.鈥�

As discussed, teaching guidelines have substantially changed over the years. If your practice or teaching facility is still following the old CMS guidance, your anesthesia department will benefit by making sure the most current guidelines available are followed. If you do not subscribe to your local Medicare Administrative Contractors (MAC), sign up for updates. If coders are not able to keep up to date by attending meetings or by subscribing to specialty newsletters, these industry alerts and major CMS changes are typically available free of charge and all one needs is an email address.

Kelly D. Dennis, MBA, ACS-AN, CANPC, CHCA, CPMA, CPC, CPC-I, Perfect Office Solutions