A recent round of edits to the Centers for Medicare & Medicaid Services' (CMS) interpretive guidelines has caught the attention of experts in the field for its focus on anesthesia guidelines.
Any hospital that accepts Medicare and Medicaid reimbursement must follow these interpretive guidelines, explains Sue Dill Calloway, RN, MSN, JD, director of hospital risk management for The Doctor's Company, in Columbus, OH.
These guidelines must be followed for all patients in the hospital, such as commercial payer or no pay patients, and not just Medicare and Medicaid patients. The guidelines do not apply to critical access hospitals, which have their own manual.
The final memo was 17 pages long and completely rewrites the CMS anesthesia section standards. Every anesthesiologist, certified registered nurse anesthetist (CRNA), or anesthesiology assistant that practices in a hospital, including surgery, post-anesthesia care unit (PACU), outpatient department, and obstetrics, should be aware of these new guidelines along with all Prospective Payment System hospitals.
These standards are also of interest to places where moderate sedation may be given, says Dill Calloway, such as in the emergency department or endoscopy unit. It is important to note that deep sedation is anesthesia, which can only be done by an anesthesiologist, qualified physician, CRNA, or anesthesiology assistant.
A dentist, oral surgeon, or podiatrist, who is qualified under state law, may also administer anesthesia. The hospital's policy must address the circumstances under which a doctor, who is not an anesthesiologist, is permitted to administer anesthesia and hospitals must follow accepted standards of anesthesia care when establishing their policy and procedure. The American Society of Anesthesiology (ASA) has a number of position statement and guidelines.
The anesthesia standards start at tag number 1000. The CMS hospital manual is 370 pages long and has 1,163 tag or section numbers. The new standards go into detail on the differences between anesthesia and analgesia.
In analgesia, the patient does not lose consciousness and is given medication for pain relief by blocking pain receptors. Anesthesia is the administration of a medication to produce blunting or loss of pain perception, voluntary and involuntary movement, autonomic function, and memory or consciousness.
The anesthesia standards apply to general anesthesia, regional, Monitored Anesthesia Care (MAC), and deep sedation can be done by an anesthesiologist, qualified physician, CRNA, or anesthesiology assistant.
Topicals, locals, minimal sedation, and moderate sedation can be done by an appropriately trained medical practitioner within their scope of practice, such as an emergency department physician or gastroenterologist. Also, these four services (minimal, local, minimal sedation, and moderate sedation) are not subject to the anesthesia administration and supervision requirement.
"Often these are administered by a RN," says Dill Calloway. "The hospital must have a policy detailing who can administer these that is consistent with the state scope of practice."