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Certified Registered Nurse Anesthetists Exemption

December 06, 2017

Did you know rural hospitals and critical access hospitals (CAHs) or hospitals/CAHs reclassified to a rural area may qualify for reasonable cost reimbursement of anesthesia services performed by a qualified non-physician anesthetist if they meet certain criteria and obtain approval for cost reimbursement?

This is commonly referred to as the certified registered nurse anesthetists (CRNA) exemption because the services are exempt from being billed to Medicare Part B on the Centers for Medicare and Medicaid Services (CMS) 1500 form. Instead, services are included on the Medicare Part A billing form UB-04 CMS-1450. Non-physician anesthetists are defined as CRNAs and anesthesiologist’s assistants (AAs).

This is an annual election and is made on a calendar-year basis. You can find the manual reference for election of cost reimbursement for CRNA at CFR 42 Section 412.113(c).

Review Action Items
All hospitals pursuing CRNA cost reimbursement for anesthesia services for any calendar year must submit a written request to their Medicare Administrative Contractor (MAC) before January 1 of the applicable calendar year.

The written request must include the following information:

  • Written, signed and dated agreements with the CRNA/AAs under contract or employment for services to be rendered during the calendar year. The hospital/CAH may employ or contract with more than one anesthetist; however, the total number of hours of service furnished by the anesthetist(s) may not exceed 2,080 hours per year.
  • Data for its entire patient population demonstrates that its volume of surgical procedures (inpatient and outpatient), requiring anesthesia services, for the prior year did not exceed 800 procedures. For administrative purposes, the volume of surgical procedures for the immediately-preceding year is the sum of the surgical procedures for the 9-month period ending September 30, annualized for the 12-month period.
  • Each qualified non-physician anesthetist employed or under contract with the hospital has agreed in writing not to bill on a reasonable charges basis for his or her patient care to Medicare beneficiaries in that hospital
  • Current CRNA/AA license(s)

Check with Your MAC
Required documentation and due dates differ among the MACs. Confirm with your MAC the necessary documents (contracts, written agreements, attestations) and due dates that must be submitted/met in order to qualify for the CRNA cost reimbursement option. Some MACs notify hospitals of their requirements if the hospital has previously qualified for the CRNA exemption. Other MACs post a reminder bulletin on their websites.

If your hospital hasn’t qualified in recent years and believes it may qualify for an upcoming calendar year, contact your MAC to determine the necessary documents and due dates. Regardless of the individual MAC requirements, all requests must be made prior to January 1.