Anesthesiology is on the CMS Office of Inspector General for the second year in a row. Following 2014, the 2015 Work Plan released in late October, 2014, notes that audits and data from anesthesia providers will continue review by investigators from the OIG. Additionally, pain management physicians have new codes that the OIG will start reviewing to insure compliance.

Audits from anesthesia providers will continue to be reviewed by investigators from the OIG.

Audits from anesthesia providers will continue to be reviewed by investigators from the OIG.

The Main Focus of the OIG Anesthesia Investigations

The Office of the Inspector General remains concerned with Part B claims for anesthesia. By reviewing claims and data associated with them, the OIG continues searching anesthesia services claim for personally provided anesthesia services in a continuing effort to find if the use of the AA modifier, meets Medicare requirements. Using the correct Medicare billing code determines if the service physician personally delivered the service or the service was by a non-physician under medical direction. Anesthesia services coded and billed with the AA modifier, pay twice the amount of a medically directed anesthesia service.

Per the OIG Work Plan for 2015:

We will review Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements. We will also determine whether Medicare payments for anesthesia services reported on a claim with the “AA” service code modifier met Medicare requirements. Physicians report the appropriate anesthesia modifier code to denote whether the service was personally performed or medically directed. (CMS, Medicare Claims Processing Manual, Pub. No. 100-04, ch. 12, § 50) Reporting an incorrect service code modifier on the claim as if services were personally performed by an anesthesiologist when they were not will result in Medicare’s paying a higher amount. The service code “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, whereas the QK modifier limits payment to 50 percent of the Medicare-allowed amount for personally performed services claimed with the AA modifier. Payments to any service provider are precluded unless the provider has furnished the information necessary to determine the amounts due. (Social Security Act, §1833(e).)

The OIG’s interest, simply put, is to check data to search out claims that are incorrectly coded with the AA modifier, when the claim should have had the QK modifier.

The OIG has no interest if the error was inadvertently done by your billing staff or your outside billing service. The person who gets the payment, in the eyes of the OIG is the responsible party.

Pain Management

Pain management saw significant code changes. These new codes go into use Jan. 1, and the OIG will audit pain management claims to support their correct use.

New Billing Codes

Among several new pain management codes for 2015, there are six important new codes for Vertebroplasty and Kyphoplasty procedures. They are:

  • 22510 – Percutaneous vertebroplasty (bone biopsy included when performed), 1 vertebral body, unilateral or bilateral injection, inclusive of all imaging guidance; cervicothoracic
  • 22511 – … lumbosacral
  • 22512 – … each additional cervicothoracic or lumbosacral vertebral body (List separately in addition to code for primary procedure)

NOTE: *** (Use 22512 with 22510, 22511)

(Do not report 22510, 22511, 22512 with 20225, 22310, 22325, 22327 when performed at the same level as 22510, 22511, 22512)

  • 22513 – Percutaneous vertebral augmentation, including cavity creation (fracture reduction and bone biopsy included when performed) using mechanical device (e.g., kyphoplasty), 1 vertebral body, unilateral or bilateral cannulation, inclusive of all imaging guidance; thoracic
  • 22514 – … lumbar
  • 22515 – … each additional thoracic or lumbar vertebral body (List separately in addition to code for primary procedure).

NOTE: *** (Use 22515 with 22513, 22514)

NOTE: *** (Do not report 22513, 22514, 22515 with 20225, 22310, 22315, 22325, 22327 when performed at the same level as 22513, 22514, 22515).

These are the six replacement codes for 2014’s codes 22520 to 25225. Using these codes calls for the use of modifier unilateral or bilateral. Bilateral procedures use Modifier 50, for right size procedures use RT and for procedures performed on the left side of the body use LT. In addition, never use modifier 51 with the add-on codes 22512 and 22515.

NOTE: All of the six new codes include moderate sedation indicated by a red bull’s-eye. Note that 22510 billed with cervicothoracic replaces the unlisted code “unlisted procedure, spine” used through the last day 2014. The new code allows for billing for the cervical region.

NOTE: Perhaps, one of the most painful changes is that starting January 1, 2015 these codes include “all imaging guidance” meaning billing for radiological guidance is no longer allowed. Expect audits to make sure of compliance with this rule.

There are many other code changes in pain management, set by CMS. The Work Plan for 2015 looks for retroactive review of anesthesia as well as current reviews for compliance. Audits for Pain Management compliance with the new coding will be concurrent.

Time is close, but there are a number coding seminars available through spring 2015 and beyond. These include The Advanced Institute for Anesthesia Practice Management, 2015 ASIPP Annual Meeting, and the 2015 AIAPM are just a few available meetings where anesthesia and pain management billing and coding are main areas of interest.


abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.

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