Block and Line Placement Time: Provider Documentation Protocol

-->November 8, 2012Billing & Compliance Alerts

    Block and Line Placement Time:
    Provider Documentation Protocol

    By Justin Vaughn, M.Div, CPC
    Vice President of Compliance


    As most of you know, both the American Medical Association (AMA) and the American Society of Anesthesiologists (ASA) have put forth the position that minutes spent in the placement of a post-op pain (POP) block or invasive line should not count in the calculation of total anesthesia time—where such placement occurs prior to induction of the “primary anesthetic” (e.g., general anesthesia) or after emergence.  As a result, we would like to reinforce for our providers the documentation protocol they should follow, and that Medac has adopted, as it concerns denoting time for block and line placement.

    Invasive Line Time

    From what providers consistently advise, invasive lines (e.g., arterial lines, central lines, Swan-Ganz catheters) are more typically placed after induction, and certainly before emergence.  Accordingly, where the provider indicates the placement of an invasive line on the anesthesia record, Medac will presume that the line was placed in the period between induction and emergence—obviating the need to document placement time (at least from a billing perspective).  We would therefore require the provider to document start/stop time of the line placement only where such placement occurs: (a) after the anesthesia start time, AND (b) prior to induction of the primary anesthetic (or after emergence).

    Post-Op Block Time
    If the provider places a post-op pain epidural or other nerve block, the provider must denote the start and stop time of that block on the anesthesia record.  If such times are not clearly indicated, an information request (IR) will be sent to the applicable provider to obtain this information.  Let me further clarify our concerns and protocol at this point:


    • As you know, waiting for responses to IRs slows down our operations and your payments.  Thus, in order to enhance the efficient flow of the claims process, we will need all providers to be consistent in providing the time parameters of the block on the record at the time of the operative session.
    • In the event that you fail to denote the block time, and, upon receiving an IR for this information, you cannot: (a) recall such time, or (b) reference any other medical records containing such time (e.g., op report), we do not wish you to “guesstimate” the start and stop time of the placement.  Instead, you will need to provide one of three statements to Medac—based on what you know to be true.  The statements should substantively mirror those in quotes below:
    1. “The block was placed prior to the anesthesia start time.” (Examples of this might be when the POP block was placed in the pre-op holding area, prior to entering the OR, or when an epidural is placed immediately after entering the OR, and the documented anesthesia start time reflects the first minute following the completion of the block placement. In such circumstances, no time needs to be deducted.)
    2. “The block was placed after the beginning of anesthesia time, but prior to induction.  The placement lasted no more than ____ minutes.” (Fill in the blank.  The number of minutes entered will be deducted from total anesthesia time.)
    3. “The block was placed after emergence, but prior to transfer of care.  The placement lasted no more than ____ minutes.” (Fill in the blank.  The number of minutes entered will be deducted from total anesthesia time.)

    The applicable statement must be sent to Medac in the course of your response to the IR.  You will also need to amend the anesthesia record so that it states:  “Block placement time not included in anesthesia time.” All amendments to medical records should be signed and dated.  The amended record should be scanned and sent to Medac, and a copy of the amended record should be provided to the facility for inclusion in the medical record.

    Medac greatly appreciates the efforts undertaken by our clients to submit the most compliant records possible.  Faithfully fulfilling the documentation requirements referenced above will serve to protect you in the event of a payor or RAC audit.  Thank you in advance for your help in this process.

    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.