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OCTOBER 21, 2015  
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CRNA Exemption Requests Due by January 1, 2016

By: Michael Smith 
 
The certified registered nurse anesthetists (CRNA) exemption request to receive cost reimbursement is due by January 1, 2016, for qualifying rural hospitals and critical access hospitals (CAHs).
 
What is it?
Anesthesia services performed by a non-physician anesthetists may qualify for cost reimbursement if the facility qualifies and if it is billed on Medicare Part A billing form UB-04 CMS-1450, instead of Medicare Part B on form CMS 1500. (A non-physician anesthetist is defined as CRNAs and anesthesiologist assistants (AAs).) This annual election is made on a calendar-year basis. You can find the manual reference for election of cost reimbursement of CRNA at CFR 42 Section 412.113(c).
 
What do I need to do to qualify?
 
Submit a written request to your Medicare Administrative Contractor (MAC) prior to January 1 of the applicable calendar year. Please note that required documentation and due dates differ among MACs, which may be earlier than January 1, but not later. Be sure to check with your MAC to verify.
 
Here is what you typically need to submit: 
  • Written, signed and dated agreements with the CRNA/AAs under contract or employment for services to be rendered during the calendar year. You 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 your entire patient population demonstrating that the 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 nine-month period ending September 30, annualized for the twelve-month period.
  • Attestations that each qualified non-physician anesthetist employed or under contract with your facility has agreed in writing not to bill on a reasonable charges basis for patient care to Medicare beneficiaries in your facility.
  • Current CRNA/AA license(s).
Will my MAC remind me?
Some MACs will notify you of their requirements if you have previously qualified for the CRNA exemption. Other MACs will post a reminder bulletin on their websites. If you haven't qualified in recent years and you believe you may qualify for an upcoming calendar year, please contact your MAC to determine the necessary documents and due dates.
 
Questions? Please contact Michael Smith or your Eide Bailly reimbursement representative.


   
Michael Smith
Health Care Reimbursement Sr. Manager

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