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MD Warrior
Status: Attending
Join Date: Apr 2007
Location: Southeast
Posts: 3,998
You all do realize that studies based on billing data can be flawed. Over 30-40% of all "QZ" billed cases are actually supervised by an Anesthesiologist. Hence, using billing data to compare outcome simply isn't valid. Many Groups simply bill "QZ" or CRNA only to avoid TEFRA; meanwhile, the CRNA is really being supervised.
The ASA estimated 30% of CRNA only/solo billing is actually MD(A) supervised anesthesia. That was in 2001. IN 2010 my opinion is the estimate is 40-50% of CRNA only billing is actually supervised by an MD (A).
What do the data show about use of the –QZ modifier?
As anesthesiologists became ever more concerned with compliance with Medicare medical direction rules, ASA suspected that many groups would choose to bill all or most care-team services as "CRNA service without medical direction," using the –QZ modifier. Taking the example of cataract surgery, 6,098,604 cataract anesthetics were performed by anesthesiologists in 1999 (and fewer than 30,000 of these were performed in physicians' private offices, incidentally). A startling total of 230,000 cataract anesthetics were billed by other physicians. Almost half of the anesthesia services for cataracts were billed with the –QZ modifier. Similar proportions are showing up for other CPT codes. This seems to validate our hypothesis that many anesthesiologists who employ nurses (and are thus able to collect Medicare payments on their behalf) are using –QZ, which pays the full Medicare allowable even when they are in fact supervising the nurses.
It is perfectly understandable that anesthesiologists do not want to risk having a Medicare auditor determine that they did not fulfill perfectly all of the requirements for submitting a "medical direction" claim. Fortunately, CMS is aware of this unforeseen use of the –QZ modifier and knows that the huge majority of anesthesia services continues to involve supervision by an anesthesiologist. It is, however, an unintended use of –QZ, not necessarily an improper one as far as CMS is concerned. CMS has never issued any statement on whether a practice may, or may not, use –QZ for incomplete medical direction.
