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Policy No: 101

Date of Origin: 04/01/2010

Section: Anesthesia

Last Reviewed: 04/01/2019

Last Revised: 04/01/2019

Approved:  04/18/2019

Effective:  05/01/2019

This policy applies only to physicians and other qualified health care professionals.



The administration of a drug or anesthetic agent by an anesthesiologist or Certified Registered Nurse Anesthetist (CRNA) for medical or surgical purposes to obtain muscular relaxation, induce partial or total loss of sensation and/or consciousness.

Modifiers P1

Current Procedural Terminology (CPT) anesthesia physical status modifier P1 represents a normal healthy patient.

Modifiers P2

CPT anesthesia physical status modifier P2 represents a patient with mild systemic disease.

Modifers P3

CPT anesthesia physical status modifier P3 represents a patient with severe systemic disease.

Modifers P4

CPT anesthesia physical status modifier P4 represents a patient with severe systemic disease that is a constant threat to life.

Modifers P5

CPT anesthesia physical status modifier P5 represents a moribund patient who is not expected to survive without the operation.

Modifers P6

CPT anesthesia physical status modifier P6 represents a declared brain-dead patient whose organs are being removed for donor purposes.

Policy Statement

Anesthesia services should be reported using the appropriate codes from the anesthesia section of the CPT manual. Physical status modifiers P1 – P6 may be appended to the anesthesia code when applicable.

Anesthesia time begins when the anesthesiologist begins to prepare the patient for anesthesia care in the operating room or in an equivalent area and ends when the anesthesiologist is no longer in personal attendance, i.e., when the patient is safely placed under post-anesthesia supervision. The time reported should be coded in minutes in the units field of the billing format.

Services performed in conjunction with a surgical anesthetic are considered an integral part of that anesthesia service and therefore not eligible for separate reimbursement. These services include but are not limited to:

  • Arterial blood gas analysis/monitoring
  • Blood pressure monitoring
  • Carbon dioxide monitoring
  • Moderate conscious sedation
  • EEG/EKG monitoring
  • Evaluation & management services
  • Field avoidance
  • Heparin analysis
  • Intraoperative monitoring
  • Esophageal doppler hemodynamic management
  • Intubation
  • Local anesthesia (for regional or field block)
  • Nerve block (except as noted in this policy)
  • Oximetry/pulse oximetry
  • Patient controlled analgesia
  • Patient position
  • Regional IV of local anesthetic
  • Supplies and equipment
  • Ventilator set-up and/or management

Postoperative pain management services are generally provided by the surgeon who is reimbursed under a global payment policy related to the procedure. These services shall not be reported by the anesthesia practitioner unless separate, medically necessary services are required that cannot be rendered, and have been requested, by the surgeon.

Epidural for Postoperative Pain

The pre-operative placement of an epidural catheter for postoperative pain relief is eligible for separate reimbursement to a provider other than the attending surgeon when:

  1. the epidural catheter is not used as the primary surgical anesthetic, and
  2. the appropriate epidural catheter code is submitted as a distinct procedural service

The reimbursement made for the placement of an epidural catheter includes payment for all related professional service(s) on that same date of service, including but not limited to: writing orders for medication, services related to the maintenance of the epidural catheter, services related to care of patient's pain and any injections of an anesthetic substance.

Daily management of an epidural or subarachnoid drug administration (CPT code 01996) is eligible for reimbursement once per date of service for up to three postoperative days beginning the day after the surgery. Charges for four or more days of this service may be reviewed for possible reimbursement. Code 01996 is not eligible for reimbursement on the day the epidural catheter was placed.

Nerve Blocks

An epidural or peripheral nerve block injection for postoperative pain management in patients receiving general anesthesia, spinal (subarachnoid injection) anesthesia, or regional anesthesia by epidural injection may be administered preoperatively, intraoperatively, or postoperatively.

Nerve blocks administered by an anesthesiologist or CRNA as a component of the anesthesia are not eligible for separate reimbursement as they are considered a component of the anesthesia. Nerve blocks administered by an anesthesiologist or CRNA specifically for postoperative pain management are eligible for separate reimbursement. Modifier 59, XE or XU should be appended to the nerve block code.

When eligible for separate reimbursement, the nerve block code should be billed consistent with other non-anesthesia CPT codes and not billed using ASA units (base + time).


Acupuncture procedure codes when used as an anesthetic are not eligible for reimbursement.

Anesthesia by Surgeon

Moderate sedation is eligible for separate reimbursement to the surgeon if:

  1. Medicare's National Correct Coding Initiative (NCCI) does not deny the moderate sedation code as included in the primary procedure.
  2. Our health plan's Correct Code Editor (CCE) does not deny the moderate sedation code as included in the primary procedure.

Reimbursement for all other methods of delivering anesthesia will be denied, including but not limited to, nerve blocks, local, topical and regional anesthesia services, when provided by the same physician performing the medical or surgical service.

Stand-by Anesthesia

Stand-by anesthesia or trauma team stand-by anesthesia do not provide direct patient care and therefore are not eligible for separate reimbursement.


Centers for Medicare & Medicaid Services, Medicare Claims Processing Manual, Chapter 12, Section 50 "Payment for Anesthesiology Services"

National Correct Coding Initiative Coding Policy Manual for Medicare Services (Coding Policy Manual). Chapter 2

Cross References

Anesthesia Reimbursement

Modifiers 59, XE, XP, XS, XU; Distinct Procedural Service

Incidental Procedures

Correct Coding Guidelines


Your use of this Reimbursement Policy constitutes your agreement to be bound by and comply with the terms and conditions of the Reimbursement Policy Disclaimer.