RP-033 Anesthesia Services
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Reimbursement policy for anesthesia services (commercial and Medicare Advantage) including which anesthesia types qualify, time/unit calculation, modifiers, monitoring/related services billing rules, elastomeric pump supplies, position/physical status units, dental and obstetrical anesthesia guidance, and codes not separately reimbursed.
Clarified section for Screening Colonoscopy code 00812 (April 2025 bulletin entry).
Administrative policy review with no changes in policy direction (February 2024).
Added Dental, Labor and Delivery sections (August and October 2019 entries).
Added note the plan will not separately reimburse codes 99100, 99116, 99135, 99140 (December 2021).
Removed CPT 94770, 94750 and removed MA Medical Policy N-118 (June 2022).
Issue Date April 28, 2025 bulletin indicating clarifications and additions (page references elsewhere).
Added NY region applicability with note for NY under Modifying Units section (October 2021).
Added Dental, Labor and Delivery guidance to policy (08/2019).
Added Medicare Advantage note under Modifying Units (07/2021).
Added Dental, Labor and Delivery (08/2019).
Added additional verbiage related to Dental, Labor and Delivery (10/2019).
Policy summary and scope
This is the Plan's anesthesia services reimbursement policy for Commercial and Medicare Advantage markets (applicable in PA, WV, DE and NY as noted) that follows CPT conventions and aligns with CMS guidance (CMS Online Manual Publication: 100-04, Ch.12, Sec.50). It directs payment based on base units, time units (1 time unit = 15 minutes; total minutes reported in the 'days or units' block are converted by The Plan by dividing by 15 and rounding to one decimal place, e.g., 48 minutes = 3.2 time units), and applicable modifiers to denote performer/direction/supervision (for example AA, QK, QX, QY, QZ, G8, G9, AD, QS).
Coverage criteria and adjudication rules
Types of anesthesia eligible for reimbursement
Covered types of anesthesia include the following. Local infiltration (A9270) is considered direct infiltration of the incision/wound/lesion and is not covered as an anesthesia service.
Eligibility for nerve block/injection anesthesia codes 01991/01992 and local anesthesia exclusion
Anesthesia for diagnostic or therapeutic nerve blocks/injections (CPT 01991, 01992) and local anesthesia rules:
Anesthesia prior to postponement/aborted surgery
Guidance for adjudication when anesthesia is provided prior to postponement, cancellation, or abortion of surgery:
Monitoring and intraoperative supportive services (bundling rules)
Monitoring and related intraoperative/supportive services billing and bundling rules:
Elastomeric Infusion Pump and Catheter Coverage
Elastomeric infusion pump and catheter coverage and reimbursement rules:
Operational payment rules, modifiers, units, and bundling (consolidated)
Comprehensive operational and payment rules that apply across anesthesia services (consolidated):
Time units, base units, modifying units and payment calculation
Anesthesia time reporting and time units
Time must be indicated on all anesthesia claims and converted to 15‑minute time units; special rule for conscious (moderate) sedation:
Calculation of reimbursement and Base Unit and Multiple Procedure Rule
How reimbursement is calculated and rule when multiple procedures performed:
Modifying units reimbursement and Modifying Units (Flat Fee Codes)
Rules for modifying (flat‑fee) circumstance codes and handling for Medicare Advantage/NY products and criteria for specific codes:
Physical Status Modifiers and Allowed Units (Commercial Only)
Physical status modifiers P1–P6 definitions and allowed units (Commercial only):
Codes: applicable, not separately reimbursed, modifiers
| 00811 | Anesthesia for lower intestinal endoscopic procedures - diagnostic/when screening converted to diagnostic (use PT modifier as applicable) |
| 00812 | Anesthesia for lower intestinal endoscopic procedures - screening colonoscopy |
| 01991 | Anesthesia for diagnostic or therapeutic nerve blocks and injections (eligible when performed by a different provider) |
| 01992 | Anesthesia for diagnostic or therapeutic nerve blocks and injections (eligible when performed by a different provider) |
| 01958 | Anesthesia for obstetric procedures (labor) |
| 01960 | Anesthesia for labor and delivery |
| 01961 | Anesthesia for labor and delivery |
| 01962 | Anesthesia for labor and delivery |
| 01963 | Anesthesia for labor and delivery |
| 01965 | Obstetrical anesthesia |
| 99100 | Modifying unit - age (not separately reimbursed per policy) |
| 99116 | Modifying unit - total body hypothermia (not separately reimbursed per policy) |
| 99135 | Modifying unit - controlled hypotension (not separately reimbursed per policy) |
| 99140 | Modifying unit - emergency (not separately reimbursed per policy) |
| AA | Anesthesia services performed personally by the anesthesiologist |
| AD | Medical supervision by a physician; more than 4 concurrent anesthesia procedures |
| G8 | Monitored anesthesia care (MAC) for deep complex/complicated or markedly invasive surgical procedures |
| G9 | Monitored anesthesia care for patient with history of severe cardio-pulmonary condition |
| QK | Medical direction of two, three or four concurrent anesthesia procedures involving qualified individuals |
| QS | Monitored anesthesia care service (informational) |
| QX | CRNA service with medical direction by a physician |
| QY | Medical direction of one CRNA by an anesthesiologist |
| QZ | CRNA service without medical direction by a physician |
| 59 | Distinct procedural service - use to report monitoring/services independent from anesthesia when supported |
| D9222 | Deep sedation/general anesthesia, initial 15 minutes |
| D9239 | IV moderate (conscious) sedation/analgesia, initial 15 minutes |
| D9223 | Deep sedation/general anesthesia, each subsequent 15-minute increment |
| D9243 | IV moderate (conscious) sedation/analgesia, each subsequent 15-minute increment |
| A9270 | Local anesthesia (direct infiltration of incision/wound/lesion) - not a covered service/separately reimbursable |
Billing, modifier and documentation actions (what providers must do)
Report anesthesia time and conversion
Report the actual anesthesia time spent administering anesthesia as minutes in the claim 'days or units' block; the Plan will convert total minutes to time units. Time units = total minutes ÷ 15, rounded to one decimal place. For moderate (conscious) sedation, report units (not minutes).
- Conversion example: 48 minutes = 48 ÷ 15 = 3.2 time units
Do not bill monitoring separately with anesthesia / Use modifier 59 when independent
Monitoring and other supportive services performed as part of anesthesia care are bundled into the anesthesia allowance and are not separately reimbursed when reported on the same date of service. If a monitoring/supportive service is independently performed and clearly distinct from the anesthesia service, it may be reported separately only with modifier 59 and documentation that supports its independent performance.
- Common monitoring examples: ECG/EKG monitoring, pulse oximetry (oxygen saturation), end-tidal CO2 monitoring (capnography), blood pressure, temperature, respiratory monitoring.
- If itemized charges for monitoring/support are submitted the Plan will combine them with the anesthesia charge and reimburse only the anesthesia.
- When modifier 59 is used, the patient medical record must support its use per CPT guidance.
- Participating/network providers may not separately bill the member for bundled monitoring services.
Documentation for directed anesthesia
Directed anesthesia must be supported by the anesthesia record and clinical documentation showing the physician's pre-anesthetic exam, prescribed anesthesia plan, participation in induction/emergence or the most demanding portions of care, monitoring, and post-anesthesia care. When physician and CRNA both bill full fees for the same case, documentation from both providers must support payment splits or full fees.
- Required documentation: pre-anesthetic examination and evaluation, anesthesia plan, record of personal participation in induction and/or emergence when billed, monitoring notes, and post-anesthesia care.
- Identify physicians in group practices explicitly in the record to support who performed or directed services.
- When payment is requested for both physician and CRNA full fees, submit documentation from both providers that supports medical necessity for dual payment and the distinct services performed.
Obstetrical add-on codes: billing and rejection risk
Obstetrical anesthesia add-on codes must never be billed as standalone services and must be reported on the same date of delivery as the primary anesthesia code. Mismatched dates, missing the required primary code, or billing these add-ons alone will result in claim rejection or denial.
Elastomeric pump and catheter billing
Catheter insertion and removal for continuous local analgesia delivered via elastomeric pumps are included in the surgical allowance and are not separately reimbursable. Elastomeric pump supplies (A4305, A4306) are most commonly reported by facilities; physician reporting is subject to customer or group benefits.
Do not separately reimburse listed modifying unit codes
The Plan will not separately reimburse the listed modifying unit codes. Exceptions for Medicare Advantage or New York regional rules may apply as noted in policy.
Dental anesthesia billing units
For dental anesthesia, bill the initial 15-minute unit on one line and subsequent 15-minute increments on separate lines using the appropriate CDT codes and units.
- Initial 15 minutes: D9222 or D9239
- Subsequent 15-minute increments: D9223 or D9243
Aborted or cancelled surgery billing
When surgery is aborted or cancelled, follow these billing rules: if surgery is cancelled because of the anesthesiologist's preoperative appraisal, reimbursement may be considered as a consultation per member benefits. If surgery is aborted after induction, reimbursement is based on 3 basic units plus time units multiplied by the conversion factor. Documentation of events and anesthesia records is required.
- Cancelled due to anesthesiologist pre-op appraisal: may bill as consultation (coverage determined by member benefits).
- Aborted after induction: reimbursement = 3 base units + time units × conversion factor; submit anesthesia record.
- If anesthesia is reported under an NOC/NOS code for postponement, the Plan will adjudicate per policy guidelines.
- Detailed documentation and medical records must accompany appeals or requests for consideration.
Report appropriate anesthesia modifiers
Append the appropriate anesthesia modifiers to claim lines to denote who performed, directed, or supervised the service and to indicate patient physical status. QS is informational only and time must still be reported; other modifiers affect payment methodology.
- Key anesthesia modifiers: AA (anesthesiologist performed personally), AD (medical supervision >4 concurrent procedures), QK (medical direction of 2–4 concurrent CRNAs), QX (CRNA service with physician direction), QY (medical direction of one CRNA), QZ (CRNA service without direction), G8 (MAC for deep complex procedures), G9 (MAC for severe cardio-pulmonary condition), QS (monitored anesthesia care — informational).
- Physical status modifiers: P1, P2, P3, P4, P5, P6 — report as applicable.
- QS modifier is informational only; actual anesthesia time must still be reported on the claim line.
- When reporting directed/delivery scenarios, ensure modifier use is accompanied by supporting documentation per policy.
Key terms and operational definitions
Common billing questions
Q&A — Reporting anesthesia time & monitoring
Quick actionable callouts
Policy updates and material changes
Added 62273, 62281, 62282, 01967-01969; added Epidural Anesthesia Care section; clarified direction for modifiers QK and QY.
Clarified section for Screening Colonoscopy code 00812.
Policy revised (April 2026 revision noted in header).
Removed CPT 94770 and 94750 and removed Medicare Advantage Medical Policy N-118.
Added note that the Plan will not separately reimburse codes 99100, 99116, 99135, and 99140.
Added NY region applicability with note for NY under Modifying Units section.
Administrative policy review with no changes in policy direction.
Added Dental, Labor and Delivery guidance to policy (Dental anesthesia CDT billing rules and obstetrical anesthesia add-on code rules were added).
Added additional verbiage related to Dental, Labor and Delivery.
Implementation / Issue date (Effective March 12, 2018).
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