CRNA Supporting Documentation Requirements Due by Dec. 31, 2023

Published 12/04/2023

To Maintain CRNA Status
To maintain certified registered nurse anesthetist (CRNA) eligibility for reasonable cost payment under the Code of Federal Regulations paragraph (c)(2)(1), you must demonstrate prior to January 1 of each respective year that for the prior year its volume of surgical procedures requiring anesthesia service did not exceed 800 procedures.

Supporting Documentation

  • A signed statement by each CRNA/AA agreeing that he/she will not bill on a fee schedule basis for patient care services. This statement must include the current review period.
  • Supporting documentation to define the total number of hours spent at the facility, whether performing anesthesia or other services
  • Copies of written, signed, and dated agreements of CRNA/AA contracts during the period of January 1 through December 31. If the CRNA/AA is employed by the hospital/CAH, the CRNA exemption request submitted by the facility should indicate that the CRNA/AA is an employee of the hospital/CAH. Hospitals or CAH may employ or contract with more than one anesthetist, however, the total number of hours of service furnished by the anesthetists may not exceed 2,080 hours per year.
  • Surgical 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 through September 30. Annualized surgical procedures for this period should not exceed 800 surgeries.
  • The log must include:
  1. Dates (surgical)
  2. Patient name
  3. Surgeon name
  4. Anesthetist's name (CRNA/AA)
  5. Type of anesthesia
  6. Type of surgical procedure
  • Documentation that the hospital or CAH is located in a rural area as defined for prospective payment system purposes or has been reclassified as rural under 42 CFR 412.103

Please submit written requests for CRNA status evaluation to our office prior to January 1, 2024. This is a mandated deadline, and we cannot make exceptions for late receipt of information. Manual reference for election of cost reimbursement for CRNA services can be found at 42 Code of Federal Regulations (CFR) 412.113(c).

Due to the presence of PHI/PII, data should be password protected. Please include a contact name and telephone number so a reimbursement consultant can obtain the password.

Please submit all documentation to JMReimbursement@Palmettogba.com.


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