CurrentEmblemHealthPolicy RPC20210014

Assistant at Surgery - Modifiers 80/81/82 and AS (Commercial)

Governs reimbursement rules for assistant-at-surgery services (physician and non-physician assistants) and required modifiers for claims submitted to EmblemHealth; affects surgeons, assistant surgeons, and other qualified health care professionals billing EmblemHealth products.

Policy Summary

PayerEmblemHealth

PolicyAssistant at Surgery - Modifiers 80/81/82 and AS (Commercial)

Policy CodePolicy RPC20210014

Change TypeClarification / Non‑material updates

Effective DateJan 1, 2021

Next Review Date

Key ActionClaims for assistant-at-surgery services must be billed under each provider's own rendering NPI; billing assistant services under the surgeon's number is inappropriate.

SourceLink

POLICY UPDATE CHANGES

Clarified that each provider must bill under their own rendering provider NPI.

Added note that an assistant surgical reduction may apply to supplemental codes effective 4/1/2025.

Transferred policy content to company-branded template.

1assistant surgeon reimbursable per procedure

SI=2codes eligible

SI=1/9codes not eligible

AS,80,81,82

Trek Health ingests and normalizes Transparency in Coverage data and payer policy updates to give provider organizations a clear view of how commercial reimbursement behaves across markets, payers, and services. Our platform transforms raw payer disclosures into structured intelligence that supports contract evaluation, payer negotiations, and service line strategy. By combining market benchmarks with ongoing policy visibility, Trek helps teams identify variability, risk, and opportunity in commercial reimbursement. The result is faster insight, stronger negotiating positions, and more informed financial decisions.

applicable modifiers

Assistant-at-Surgery Coverage Criteria

Assistant-at-Surgery coverage criteria

Covered when ALL of the following are met:

ALL of the following

Only procedure codes with a CMS assistant surgeon indicator of '2' are eligible for assistant surgeon reimbursement; procedure codes with indicator '1' or '9' are not eligible for assistant surgeon reimbursement; codes with indicator '0' are not eligible on initial adjudication but may be reviewed for reimbursement upon written appeal with supporting medical necessity documentation.
Only one assistant surgeon is reimbursable per procedure; a second assistant surgeon will be considered only via written appeal with documentation demonstrating medical necessity.
The assistant surgeon must report the same procedure code(s) as the primary surgeon (exception: when the surgeon bills a global code, the assistant must bill the surgery-only code).
Physician assistants/other qualified health care professionals use modifier AS; physician assistants serving as assistant surgeons use modifiers 80, 81 or 82 as appropriate; assistants must submit the identical procedure code(s) as the primary surgeon when applicable.
Each provider must bill under their own rendering provider NPI; it is inappropriate to bill assistant-at-surgery services rendered by surgical technicians, scrub nurses, or other non-qualified assistants under the surgeon's provider number.
The allowable amount for assistant-at-surgery services will be no more than the allowable amount payable to the primary surgeon for the covered services assisted.

An assistant surgical reduction may apply to supplemental codes.

Modifiers, Status Indicators, and Allowed Assistants

Assistant-at-surgery modifiersModifier

80	Assistant Surgeon (physician)
81	Minimum Assistant Surgeon
82	Assistant Surgeon when qualified resident not available
AS	Assistant at surgery by PA/NP/CNS (non-physician)

Assistant-at-surgery modifiers (descriptions)Modifier

80	Assistant Surgeon: Surgical assistant services may be identified by adding modifier 80 to the usual procedure number(s).
81	Minimum Assistant Surgeon: Minimum surgical assistant services are identified by adding modifier 81 to the usual procedure number.
82	Assistant Surgeon (when qualified resident surgeon not available): The unavailability of a qualified resident surgeon is a prerequisite for use of modifier 82 appended to the usual procedure code number(s).
AS	Physician assistant, nurse practitioner, or clinical nurse specialist services for assistant at surgery.

CMS Assistant Surgeon Status Indicatorsmixed

SI=2	Assistant at surgery may be paid
SI=1	Statutory payment restriction; assistant at surgery may not be paid
SI=0	Payment restriction applies unless medical necessity documentation submitted on appeal
SI=9	Assistant at surgery concept does not apply

Allowed assistant surgeons per procedure

Maximum assistants reimbursedOnly one assistant surgeon is reimbursed per procedure code/surgery.

Second assistant processA second assistant surgeon will be considered only via a written appeal with documentation demonstrating medical necessity.

Code reporting requirementThe assistant surgeon must report the same procedure codes as the primary surgeon (exception when the surgeon bills a global code).

Billing, Appeals, and Operational Requirements

Prior Authorization

Second or restricted assistants require written appeal with medical necessity

A second assistant surgeon will be considered only on the basis of a written appeal when documentation of medical necessity for the second assistant surgeon is submitted. Procedure codes with a CMS assistant surgeon indicator of '0' are not eligible on initial adjudication but may be reviewed for reimbursement upon written appeal with supporting medical necessity documentation. Procedure codes with indicators '1' or '9' are not eligible and have no criteria for approval on appeal.

Submit a written appeal detailing the medical necessity for a second assistant surgeon.
For codes with CMS SI=0, include supporting medical documentation to justify payment.
Do not expect appeal approval for codes with CMS SI=1 or SI=9; CMS indicates assistants cannot be paid on these procedures.

Documentation Required

Assistant services must be billed under each provider's rendering NPI

Key Definitions

Allowed Amount

DefinitionAllowed Amount = dollar amount eligible for reimbursement to the physician or other qualified health care professional on the claim (often called allowed amount or eligible expense).

Assistant-at-Surgery capThe allowable amount for services from an Assistant‑at‑Surgery is no more than the allowable amount payable to the primary surgeon for the covered services assisted.

ContextAllowed Amount is used to determine the payment eligible under the member's benefit plan for the provider submitting the claim.

Assistant-at-Surgery / Assistant Surgeon

DefinitionAssistant‑at‑Surgery/Assistant Surgeon = a physician or other qualified health care professional who is assisting the physician performing a surgical procedure.

Role

Policy Summary

PayerEmblemHealth

PolicyAssistant at Surgery - Modifiers 80/81/82 and AS (Commercial)

Policy CodePolicy RPC20210014

Change TypeClarification / Non‑material updates

Effective DateJan 1, 2021

Next Review Date

Key ActionClaims for assistant-at-surgery services must be billed under each provider's own rendering NPI; billing assistant services under the surgeon's number is inappropriate.

SourceLink

On This Page

Claims for assistant-at-surgery services must be billed under each provider's own rendering provider NPI; it is inappropriate to bill assistant services rendered by a surgical technician, scrub nurse, or other surgical assistant under the surgeon's performing provider number.

Each assistant must report services using their own rendering NPI on the claim.
Do not bill assistant-at-surgery services under the surgeon's NPI (no 'incident to' billing for these assistants).

Assists the primary surgeon during the surgical procedure and must report the appropriate procedure codes when billing.

Billing noteAssistant must report the same codes as the surgeon unless the surgeon bills a global code; then the assistant bills the surgery‑only code.

Health Care Professional (PA, CNS, NP)

DefinitionHealth Care Professional = Physician Assistant (PA), Clinical Nurse Specialist (CNS), or Nurse Practitioner (NP) who does not hold an MD or DO degree.

QualificationThese non‑physician clinicians are considered qualified health care professionals for assistant‑at‑surgery services when applicable.

Modifier guidanceNon‑physician assistants use modifier AS when applicable (see coding section).

Same Individual (physician or other qualified health care professional)

DefinitionSame Individual = the same individual rendering health care services reporting the same Federal Tax Identification number.

ImplicationUsed to identify when services on a claim were rendered by the identical provider for Federal reporting and billing purposes.

Billing practiceEach provider must bill under their own rendering NPI; services rendered by non‑qualified personnel should not be billed as assistant‑at‑surgery under the surgeon's number.