CMS Responds to ASA’s Hospital Interpretive Guideline Concerns

The Centers for Medicare and Medicaid Service sent a response to the American Society of Anesthesiologists providing context and rationale for recent updated Interpretive Guidelines for the Medicare Hospital Conditions of Participation, according to an ASA news release.

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CMS addressed the ASA’s concerns in five areas: formal rulemaking, one anesthesia service, labor epidurals, pre-anesthesia evaluation and post-anesthesia evaluation.

CMS supported its decision to allow CRNAs to administer labor epidurals as long as they were analgesic, meaning they relieve pain and do not inhibit motor function, according to the CMS’s letter. CMS also noted that in cases where mothers require an operative delivery, CRNAs must be supervised by the operating practitioner or anesthesiologist. The agency stressed the need for constant communication among practitioners and the patient at all times throughout the process.

For pre-anesthesia evaluations, CMS noted in its letter that the pre-anesthesia evaluation must be completed within 48 hours of surgery, but testing and consultations may be performed in advance of the 48-hour window. CMS also recognized that post-anesthesia evaluation guidelines do not specify inpatient or outpatient procedures, but noted that hospitals should have follow-up guidelines in place so that they can evaluate a patient’s reaction within the 48-hour time frame. The agency also noted that given the wide variation in patients’ reactions to anesthesia, hospital policies and procedures should reflect this fact.

Read the ASA’s release (including both CMS’s and ASA’s letters) on the interpretive guidelines.

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