With ongoing and anticipated staffing shortages in anesthesiology, strict adherence to compliance regulations in anesthesia teaching programs is crucial. The Association of American Medical Colleges expects a shortage of 12,500 anesthesiologists by 2033 — as many providers near retirement —- underscoring the need for compliance with existing guidelines to maintain organizational integrity and ensure uninterrupted patient care.
A March 4 blog post by Coronis Health emphasizes the importance of the “Rule of Two” and clarifies how anesthesia providers must align with these guidelines.
Three takeaways:
The ‘Rule of Two’ sets clear boundaries
CMS and the American Society of Anesthesiologists explicitly limit anesthesia teachers to a maximum of two concurrent cases with residents or student nurse anesthetists (SRNAs). Violations can lead to significant compliance problems.
The guidelines specify a teaching anesthesiologist can oversee:
- Up to two resident cases
- Or, one resident case and one medically directed case
- Or, up to two SRNA cases
Similarly, teaching CRNAs cannot supervise more than two SRNA cases at a time.
The only permitted exception allows anesthesiologists to oversee up to four SRNA cases but strictly under the condition that a CRNA is continually present with each SRNA. In this scenario, the anesthesiologist medically directs the CRNAs — not the SRNAs.
Billing guidelines for teaching scenarios
Updates to the Medicare Claims Processing Manual since 2010 underline that anesthesiologists involved in resident or SRNA teaching scenarios cannot exceed two concurrent cases to bill at the personally performed (AA) modifier rate. Teaching CRNAs face identical constraints when billing for their involvement in SRNA cases.
Proactive compliance is encouraged
Anesthesia providers are strongly advised to implement clear, proactive protocols; educate their teams; and reinforce these guidelines regularly to avoid inadvertently crossing regulatory lines. Ensuring awareness of these rules is vital for maintaining compliance and avoiding potential penalties.
The post Strict anesthesia teaching limits: Key points for providers appeared first on Becker’s ASC.
