Deducting Time for Lines & Blocks
A Key Clarification of the Rule
By: Justin Vaugn, MDiv, CPC
Director of Compliance

March 21, 2011

As you know, the American Medical Association (AMA) in 2007 rendered an opinion that was later ratified by the American Society of Anesthesiologists (ASA) regarding the billing of anesthesia time in conjunction with an invasive line or post-op pain block placement.  The rule made it clear that the person providing anesthesia service could not bill for time placing such a line or block if the placement occurred prior to induction of the primary anesthetic—even if in the OR.  However, this rule raised questions among many in the anesthesia community as to how one would bill such time when two providers are involved.  These questions have now been answered.

In a March 17, 2011 letter to healthcare attorney David Vaughn, the AMA (in consultation with the ASA) advised that there are two circumstances in which time spent placing invasive lines or post-op pain blocks while in the OR, but prior to induction of the primary anesthetic, would NOT need to be deducted from total anesthesia time.  Those circumstances are as follows:

• Where a medically directing anesthesiologist places the line or post-op pain block, the time does not need to be deducted since the CRNA is providing ongoing anesthesia service during such placement.

• Where an anesthesiologist is providing ongoing anesthesia care, and one of his/her partners (a separate anesthesiologist) comes into the OR only to place the line or post-op pain block, no anesthesia time needs to be deducted since the patient has uninterrupted anesthesia care from the anesthesiologist who is handling the case.  (The AMA noted that it expected such a case involving 2 anesthesiologists to be rare.)

Though the AMA’s official notification to attorney David Vaughn does not overturn any previously published provision of the 2007 rule concerning time for lines and blocks, and though it remains subject to any payor policy to the contrary, this clarification does provide a very welcome answer to the questions many of you have posed in the last couple of years regarding the above contingencies.  I want to thank David for seeking this clarification from the AMA and for forwarding their positive answer.

The information presented herein reflects general information that is current as of the date it was first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.