Earlier this month, the HHS Office of Inspector General published an advisory opinion that permitted a pain management practice to retain the profits it received from billing for the anesthesia services that an employed CRNA provided at an ASC partially owned by the practice’s physician-owner.
As described in Advisory Opinion 21-15, a pain management practice wholly owned by one physician employed a CRNA to provide anesthesia services at the practice’s office and an ASC co-owned by the practice’s physician-owner and another physician. Pursuant to this agreement, the CRNA reassigned his billing rights to the practice while the practice assumed responsibility for the CRNA’s performance of anesthesia services, billed for the CRNA’s services, paid the CRNA a salary, and performed other duties typically expected of employers.
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