Beginning in March, the Centers for Medicare and Medicaid Services (CMS) will release Comparative Billing Reports (CBR) to some providers who perform anesthesia services.
CBRs are educational tools that reflect providers’ billing and/or prescribing patterns as compared to their peers’ patterns for the same services in their state or specialty, and nationwide. CBR 202002: Anesthesia Modifiers will focus on anesthesia services submitted with modifiers AA and AD.
Criteria for Evaluation
The following three metrics will be reviewed for all anesthesia claims:
- Percent of anesthesia services allowed with AA or AD modifiers
- Average allowed amount per claim for anesthesia services
- Average number of anesthesia units of service allowed per claim with an AA or AD modifier
For each metric, there are four possible outcomes for anesthesiologists, as their performance is compared with their peers:
- Significantly Higher — Provider’s value is greater than or equal to the 90th percentile from the state or national mean.
- Higher — Provider’s value is greater than the state or national mean.
- Does Not Exceed — Provider’s value is less than or equal to the state or national mean.
- Not Applicable (N/A) — Provider does not have sufficient data for comparison.
Physicians will receive a CBR only if their performance is significantly higher compared to either state or national averages or percentages in any of the three metrics, and they have
- at least 50 beneficiaries with claims for CPT® codes 00100 – 01999, and
- at least $20,000 or more in total allowed charges.
Anesthesiologists are specifically being targeted for upcoming CBRs because of an increase in suspected improper payments. According to CMS, the 2019 Medicare Fee-for-Service Supplemental Improper Payment Data report projected the projected improper payment rate for anesthesia, as a service type, at 7.3%, representing $156,137,236 in projected improper Medicare payments. This represents a considerable increase from the 2018 improper payment rate, which was projected at 2.0%, representing $36,427,656 in projected improper Medicare payments.
In addition, this CBR highlights the need for proper documentation of anesthesia claims, since 79.6% of the 2019 projected improper payments were due to insufficient documentation.
Unfortunately, the anesthesia CBRs do not appear to take into consideration groups that have only physician anesthesiologists, which means their AA modifier percentage will likely be 100, or the type or complexity of cases an anesthesiologist might perform, which means some groups or individuals who perform all cardiac or orthopedic cases, for instance, might naturally have higher units or allowed amounts per case.
What If I Receive a CBR?
While CMS says that receiving a CBR is not “an indication or precursor to an audit,” providers may want to prepare for that possibility by ensuring all cases are properly documented. Specifically, CMS highlighted the following from the Medicare Claims Processing Manual in their sample CBR letter: “The physician must document in the medical record that he or she performed the pre-anesthetic examination and evaluation. Physicians must also document that they provided indicated post-anesthesia care, were present during some portion of the anesthesia monitoring, and were present during the most demanding procedures in the anesthesia plan, including induction and emergence, where indicated.”
CBRs are not posted publicly. Instead, CBRs will be sent via email from CMS CBR Contractor RELI Group with the following email address: email@example.com. To ensure they receive the email, anesthesiologists should update their contact email address in the Provider Enrollment, Chain, and Ownership System. Once the CBRs have been sent, providers also can access them via the CBR portal.
To learn more about the upcoming anesthesia modifiers CBR, review the following:
- CMS’s recent announcement of the upcoming CBR
- RELI Group’s Sample Anesthesia CBR with Mock Physician data
- Upcoming Webinar reviewing the CBR 202002 on March 9, 2020
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