CRNA Exemption

InsightsClient Alert

Under the provisions at 42 CFR 412.113(c), rural hospitals (PPS and CAH) may qualify for cost reimbursement versus fee schedule for Certified Registered Nurse Anesthetists (CRNAs) and Anesthesiology Assistants (AAs) for hospital services (subunits and swing beds are not included in this exemption).

This election must be requested on a calendar year basis no later than December 31st each year.

The MACs have different due dates and processes for requesting the exemption.  See below for WPS, Novitas and Noridian guidance.

Palmetto has not posted specific guidance but requires documentation to support the request.  We suggest submitting the documentation required by WPS and Novitas.  Email requests to and

To qualify for the exemption all of the following apply.

  • The hospital must have employed or contracted with a qualified CRNA/AA to perform services as of January 1, 1988. This is a hold harmless provision.
  • The hospital must be located in a rural area or have been reclassified to rural under 42 CFR 412.103.
  • The volume of inpatient and outpatient surgical procedures requiring anesthesia services cannot exceed 800 procedures in the prior calendar year. To qualify for CY 2022, the volume of surgical procedures for the nine month period ending September 30, 2021, is annualized for the twelve month period.  If actual surgical procedures for the CY are greater than 800, the provider loses the exemption and must rebill as fee schedule.
  • The hospital may employ or contract with more than one anesthetist; however, the total number of hours of all services, not just surgery hours, furnished by the anesthetists may not exceed 2,080 hours per year. Pass-through eligibility status for the entire CY is lost if hours are exceeded, and the claims will need to be rebilled as fee schedule.
  • Each qualified CRNA/AA under contract or employed by the hospital must agree in writing not to bill for his/her patient care to Medicare beneficiaries.

Certified Registered Nurse Anesthetist (CRNA) Exemption to the Fee Schedule (

Election of cost reimbursement for CRNA services (

CRNA Exemption – JF Part A – Noridian (

For more information, please contact our Albany office at (229) 883-7878 or our Atlanta office at (404) 220-8494.

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