In December 2009, the Centers for Medicare and Medicaid Services (CMS) released revised Hospital Conditions of Participation Interpretive Guidelines for Anesthesia Services. The guidelines contained significant changes, including modifications that the industry felt required clarification.
At the heart of the discussions was the guidelines' distinction between anesthesia and analgesia and the administration and supervision of those services. On January 11, 2011, CMS released revised guidelines, addressing these issues.
Revised Interpretive Guidelines
Nationally Recognized Guidelines
CMS acknowledged, "there is often no bright line" or "clear boundary between anesthesia and analgesia." The revised guidelines noted this was particularly the case with moderate versus deep sedation and labor epidurals.
The revised guidelines, in effect, allow certified registered nurse anesthetists (CRNAs) to administer analgesic labor epidurals without supervision. The updated guidelines also allow hospitals to use different policies for different clinical settings, such as the emergency room, provided the hospital bases policies on nationally recognized standards.
Pre- and Post-anesthesia Evaluations
The revisions clarified provisions on required pre- and post-anesthesia evaluations. The changes deal primarily with timing.
Pre-anesthesia evaluation: Guidelines require documentation and completion of pre-anesthesia evaluations up to 48 hours before the start of anesthesia. CMS clarified that certain aspects of the evaluation, such as documentation of risk, may be performed prior to 48 hours, but no more than 30 days prior to the procedure. The revised language requires review and updating of all previous documentation within the required 48 hours.
Post-anesthesia evaluation: Guidelines require documentation and completion of post-anesthesia evaluations within 48 hours after the procedure or surgery. The earlier language implied the evaluation must occur in the Post Anesthesia Recovery Unit (PACU). Revised language specifies that the evaluation starts in recovery. The 48-hour requirement still applies, but the evaluation can be completed after the patient is moved to another inpatient location or discharged.