The report points out inherent issues with tightening the documentation requirements. For example, the documentation requirements state that “the surgeon documents the need for and orders a transfer of pain management.” But does that mean the surgeon needs to document personally? Many anesthesia practices rely on standing orders or have the anesthesiologist record the surgeon’s request for post-operative analgesia.
According to Anesthesia Business Consultants, the conservative interpretation of the LCD is confusing and problematic. Noridian may need to provide further guidance. Until then, Anesthesia Business Consultants encourages any anesthesiologist whose claim for pain management is denied due to lack of a surgeon’s written order to appeal the decision.
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