[Congressional Record (Bound Edition), Volume 148 (2002), Part 12]
[Extensions of Remarks]
[Pages 17201-17202]
[From the U.S. Government Publishing Office, www.gpo.gov]




A CALL FOR ACTION: THE CENTERS FOR MEDICARE AND MEDICAID SERVICES NEEDS 
               TO ADDRESS CRNA BILLING ISSUE IMMEDIATELY

                                 ______
                                 

                           HON. DOUG BEREUTER

                              of nebraska

                    in the house of representatives

                     Wednesday, September 18, 2002

  Mr. BEREUTER. Mr. Speaker, this Member wishes to submit, for the 
Congressional Record, a letter to Mr. Thomas Scully, Administrator of 
the Centers for Medicare and Medicaid Services (CMS), requesting that 
he address a Certified Registered Nurse Anesthetist (CRNA) billing 
issue immediately. This Member is taking this unusual step for 
additional visibility in the hope that this serious problem will be 
fixed immediately.

                                    Congress of the United States,


                                     House of Representatives,

                               Washington, DC, September 17, 2002.
     Mr. Thomas Scully,
     Hubert Humphrey Building,
     Washington, D.C. 20201.
       Dear Mr. Scully: On behalf of the Nebraska Hospital 
     Association, Nebraska's 56 Critical Access Hospitals (CAH) 
     and the communities they serve, I respectfully request that 
     the Centers for Medicare and Medicaid Services (CMS) address 
     a Certified Registered Nurse Anesthetist (CRNA) billing issue 
     immediately.
       As you are aware, most CAHs are eligible to bill for CRNA 
     services on a ``pass-through'' basis. This means that they 
     receive cost-based reimbursement for those CRNA services. To 
     receive periodic payments for CRNA's services, the CMS has 
     instructed Nebraska hospitals to bill these services, 
     including professional services, on a UB-92 form rather than 
     to the Medicare Part B carrier on a HCFA-1500. The hospitals 
     have also been instructed to use the revenue code ``964'' to 
     bill for the CRNA's professional services on the UB-92 form.
       However, it is my understanding that the CMS non-outpatient 
     prospective payment system code editor (OCE) will not allow 
     CRNA claims to be processed (and as such cannot be paid) with 
     revenue code 964. Consequently, Nebraska hospitals have not 
     received their Medicare payments which have been due for more 
     than a year. Many Nebraska hospitals are having their cash 
     flow suspended by hundreds of thousands of dollars in some 
     cases. Therefore, this is a significant issue to these 
     hospitals.
       We have been informed that the CMS will not be able to 
     change the 964 edit until April 1, 2003. A system fix should 
     be made now or at the next quarterly update rather than wait 
     until April 1, 2003. A temporary ``fix'' has been used by 
     other fiscal intermediaries through the use of revenue code 
     379 in lieu of 964, which is a generic ``anesthesia'' revenue 
     code. This will at least allow the hospital claims to be 
     paid. However, one or more fiscal intermediaries are 
     concerned with compliance and fraud and abuse issues and will 
     not allow hospitals to use revenue code 379 as a temporary 
     fix.
       In order for CMS to address this problem immediately, I am 
     requesting that CMS issue a letter of instruction or a 
     program memorandum to Nebraska and other fiscal 
     intermediaries (whatever document may be issued in the least 
     amount of time). This letter should be clear in its direction 
     to fiscal

[[Page 17202]]

     intermediaries to use the revenue code 379 as a temporary fix 
     in order to get the hospitals' claims processed without 
     delay. I am aware that a draft program memorandum has been 
     issued with regard to this matter. If the CMS could make that 
     program memorandum final, then fiscal intermediaries could 
     utilize revenue code 379.
       In my opinion, the CMS also needs to designate an 
     individual that fiscal intermediaries or hospital 
     associations can contact regarding critical access hospital 
     issues. This individual needs to understand how a CAH 
     operates, as well as how policies changed by the CMS will 
     affect other issues, particularly billing. The 964 revenue 
     code is a good example of problems many CAHs are 
     experiencing. I am certain that any critical access hospital 
     in Nebraska would be glad to host this individual for a tour 
     and orientation of how a CAH operates.
       Again, I respectfully request that you address this CRNA 
     billing issue immediately, as it seriously curtails the 
     financial viability of rural hospitals. I look forward to 
     your prompt response and for your information, I intend to 
     place this letter in the Congressional Record.
           Best wishes,
                                                    Doug Bereuter,
                                               Member of Congress.

     

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