CCI Medical Director Clarifies Bundling of Post-Op Blocks
By: Justin Vaughn, M.Div, CPC
Director of Compliance

1/4/2012

Many of you have voiced concerns over a recent submission found on the Anesthesia Administration Assembly (AAA) “listserv” concerning post-op pain procedures.  Specifically, the submission asserted that preoperatively or intraoperatively placed epidurals and nerve blocks may no longer be separately reimbursed, even where they are used primarily for postoperative pain control and not for the main anesthesia service.  This assertion was based on new language in CMS’s Correct Coding Initiative (CCI)—the document that addresses and defines bundling rules. 

Since this new language was vague, but nonetheless troubling, anesthesia compliance attorney David Vaughn recently wrote the CCI medical director, Dr. Niles Rosen, asking for clarification. Dr. Rosen’s response, which Mr. Vaughn was kind enough to share with me, can be summarized as follows:

• The new CCI language should not be assigned a “sinister” intent.

• Even though a pre- or intraoperatively placed nerve block will provide “some intraoperative analgesia,” one should not interpret the new CCI language to mean that the block cannot be separately reimbursed where the main anesthesia for the case was a general anesthetic.

• Unless and until CMS provides further clarification on this topic, anesthesia providers should continue to practice and bill as they have with regard to post-op pain services.

Accordingly, our clients will see no change in the submission of their post-op pain claims.  I want to thank attorney David Vaughn for eliciting and passing on this clarification.

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in the health care regulatory and compliance environments, the author's presentation of this information might become outdated.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.