AANA Update - November 29, 2018

Dear Colleagues,

It is with serious disappointment that I must update you on the latest activities of Medicare Administrative Contractor (MAC) Novitas Solutions. As you may recall, on Aug. 16, 2018, we received the good news that Novitas had decided not to implement a final draft local coverage determination (LCD) which would have made it policy to not recognize nurse anesthesia education and preparation, resulting in denials for CRNA reimbursement for facet joint injections in 11 states, the District of Columbia, the Indian Health Service, and the Department of Veterans Affairs. The LCD would have had a terrible impact on chronic pain patients, especially those in medically underserved areas, who rely on CRNAs to manage their pain and provide quality of life. The Novitas decision to not implement the LCD was the result of an aggressive, coordinated advocacy effort by the AANA. The AANA also reached an agreement with the MAC to work for up to one calendar year to reach an amicable, long-term solution regarding CRNA qualifications that would enable CRNAs to be reimbursed for interventional pain management procedures. 

In late August, AANA and Novitas leadership met in Dallas to begin negotiating a definitive resolution on CRNA reimbursement for pain-management services. During these negotiations, the AANA and NBCRNA sought provider neutrality for CRNAs and recognition by Novitas of the nonsurgical pain management subspecialty certification (NSPM-C) as sufficient training for CRNAs to qualify for reimbursement for providing facet-joint injections and other forms of pain management. In September, at the request of Novitas, the AANA submitted extensive comments to the MAC regarding CRNA pain management qualifications and certification.

On Nov. 27, Novitas pulled a fast one.

Despite assurances of open negotiation, Novitas has announced that it is lifting the hold on the LCD for facet joint injections and that the LCD will become effective on January 3, 2019. The LCD will be posted on the Novitas website on December 6. According to an email from Novitas, the language in the LCD has not been changed. Given that, we strongly suspect that Novitas also has not changed its thinking regarding CRNA education and preparation after receiving our response letter in September. Therefore, we believe at this time that Novitas intends to deny payment for facet joint injections for CRNAs who have the NSPM-C, are fellowship trained, or who have any other advanced training in interventional pain management.

While we are deeply disappointed by this turn of events, we remain determined to fight this LCD and change Novitas's mindset on CRNA pain management qualifications. As in our previous dealings with Novitas, the AANA is exploring all avenues to address this injustice—and I mean all.

I will keep you informed of further developments regarding Novitas as they occur.

Sincerely,

Garry Brydges, DNP, MBA, ACNP-BC, CRNA, FAAN