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MAC without any medication

I’m trying to find out how common this practice is— I work for a payer (workers’ comp) and there is one certain pain management practice that always bills for what they call monitored anesthesia care by a CRNA for every patient who gets a facet joint injection, sacroiliac joint injection, and maybe transforaminal ESIs too. The anesthesia record shows only monitoring of blood pressure, O2 sat, and pulse. It has brief notations of medical history such as hypertension or type 2 diabetes. It will state that no IV was started and clearly mark that no drugs were given. We have denied these and in appeals the provider says they are required by ASA guidelines to do "MAC" because of risk factors such as high blood pressure or spikes in blood sugar due to the steroids, or possible movement during the procedure due to severe pain.

If this were only in a few cases I might find it more credible, but it seems to be all of their patients. There are some patients who opt for sedation— other providers usually give moderate sedation by the physician with an RN doing the monitoring. In this practice when they do actually give sedation it’s always billed as "MAC" (01992) never moderate sedation (99152). But the main ones I’m curious about are the ones that are only monitoring. If they claim to be watching for such things as spikes in blood sugar, why do they not show any testing of blood sugar? The idea of MAC is that the anesthesia provider needs to be ready and able to increase or reduce the level of sedation quickly if there are problems. How would you do that if no IV has been started?

I’m only aware of one provider doing this regularly. I searched this forum and found a post from a few years ago saying that MAC can be for monitoring only, but the idea seems to be that it would be high risk patients. And most descriptions of monitored anesthesia care describe it as some level of sedation that due to risk factors may need to be increased or decreased. It’s never described as no sedation at all with a CRNA monitoring the patient.

Very curious to hear from people with more knowledge in this area- thanks:)

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