Most everyone has either submitted the request for the 2023 CRNA Exemption already or has provided the supporting documentation to be submitted to us. However, for those that have not already done so, the deadline to submit a request for the 2023 CRNA Exemption is December 31, 2022. The submission is done by email, so there is still plenty of time to get these submitted. The Exemption allows the hospital to receive cost reimbursement for CRNA services billed for Medicare beneficiaries, instead of the Fee Schedule payment rate.
To complete the submission requesting CRNA Exemption, the following information is needed; evidence that the hospital is located in a rural area (or an area re-classed as rural):
- Written, signed, and dated agreements with the CRNA/AAs under contract or employment for services to be rendered during the period of January 1 – December 31, 2023.
- Current CRNA/AA license(s).
- Surgical procedure logs (inpatient and outpatient) for the facility’s entire patient population demonstrating the number of surgical hours and number of surgeries requiring anesthesia services (include name of CRNA/AA and surgical hours utilized for each procedure) for the period January 1 – September 30, 2022. Annualized surgical procedures for this period should not exceed 800 surgeries. Annualized surgical hours of service furnished by the CRNA/AAs should not exceed 2,080 hours.
- Written, signed, and dated attestation agreements stating that the CRNA/AA has not and will not bill on a reasonable charge basis for his or her patient care to Medicare beneficiaries in that hospital or CAH for the period of January 1 – December 31, 2023.
For hospitals requesting the CRNA Exemption for the first time after 2016, there is an additional requirement to show that the hospital employed/contracted with a CRNA in 1988 their volume of surgical procedures requiring anesthesia services did not exceed 800 procedures during calendar year 1987. If you have received a CRNA Exemption for any year after 2016, then this documentation has been maintained and does not need to be resubmitted. If you do not have the 1987-88 documentation, we have a CMS approved attestation that can be submitted in lieu of that documentation that we can provide you to complete for submission of your request.
Also, we have a formatted attestation for the CRNA not to bill requirement, noted in #5 above, that we can provide you to be signed by the CRNA and submitted with your request.
If you have any questions about qualifying for the Exemption or need assistance with submitting your request, please feel free to contact:
- Greg Callaham – 806-776-0604, gregc@dhcg.com
- Hannah Emery – 469-596-6475, hannahe@dhcg.com
- Carolyn Wood – 469-242-6321, carolynw@dhcg.com
