Hospitals planning to request a Certified Registered Nurse Anesthetist (CRNA) pass-through exception for the upcoming calendar year must submit their applications this month. Submissions must include a letter requesting the exemption, an exemption questionnaire, and signed CRNA billing agreements. The exemption questionnaire requests data for the nine-month period of January 1, 2025 – September 30, 2025, which is then inflated to show an annual estimate. Deadlines for submission vary by MAC. Applications apply to services to be performed in calendar year 2026.
Why it matters: Qualifying hospitals receive reasonable cost reimbursement for CRNA services from Medicare. Hospitals that do not request the exemption, or do not qualify for the exemption, are paid under the Medicare physician fee schedule. Electing CRNA pass-through significantly increases the hospital’s reimbursement for these services.
Who Qualifies? Hospitals must meet the following criteria:
- Rural Location: Located in a rural area or reclassified as rural under 42 CFR 412.103.
- Procedure Volume: Performed 800 or fewer inpatient and outpatient surgical procedures requiring anesthesia in the prior calendar year.
- CRNA Hours: Total CRNA productive hours cannot exceed 2,080 hours per year.
- Billing Agreement: Each CRNA must sign an agreement stating they will not bill Medicare Part B for services rendered at the facility.
Don’t qualify for a CRNA Pass-Through Exemption? If you are a CAH, billing Method II, these practitioners can be added to receive Method II reimbursement.
Deadline
To avoid errors or delays in processing, all requests and supporting documentation should be submitted to the MACs by December 15 to ensure the exemption applies for the upcoming calendar year.
Action Steps
- Review CMS requirements carefully.
- Gather necessary documentation, which includes: a letter requesting the optional method of payment, an exemption questionnaire, and signed CRNA billing agreements. Please reach out if examples are needed.
- Submit your request to your MAC on or before the deadline.
For more details or assistance, contact your DZA representative.
