CRNAs and Chronic Pain: CMS Breaks New Ground

-->November 7, 2012Billing & Compliance Alerts

    By Justin Vaughn, M.Div, CPC

    In the Final Rule relating to the 2013 Medicare Physician Fee Schedule, released this month by CMS, the federal government has fully and officially recognized the right of certified registered nurse anesthetists (CRNAs) to enter into the practice of chronic pain management, allowing Medac to open our pain management billing and coding services to more practices.  The ruling acts to reaffirm the proposed rule that was promulgated earlier this year, and actually moves farther by authorizing a CRNA’s practice parameters, and thus reimbursement, to be based on the CRNA scope of practice laws and regulations of each state.  Theoretically, this means that CMS could sign off on many other CRNA services—in addition to anesthesia, acute pain and chronic pain—based on the extent of a given state’s scope of practice rules. This means that some practices may be eligible for Medac’s full suite of pain management billing and coding services.

    The Final Rule states, in pertinent part:
    “Therefore, we are revising §410.69(b) to define the statutory benefit category for CRNAs, which is specified as ‘anesthesia and related care,’ as ‘those services that a certified registered nurse anesthetist is legally authorized to perform in the state in which the services are furnished.’”
    Accordingly, if you wish to know whether or not CRNAs can submit claims to Medicare for pain management services in your particular state, you will need to:  (a) determine if that state’s legislature has adopted a scope of practice for CRNAs (such as a “Nurse Practice Act”), or alternatively has authorized the executive branch to produce regulations in this regard, and (b) determine if that scope of practice includes chronic pain management services. The Final Rule will take effect January 1, 2013.

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in the health care regulatory and compliance environments, the author’s presentation of this information might become outdated.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