Vendors are approaching many pain clinics with offers to provide either CCM, RPM, or RTM services.  In most of the proposals my clients send me, the compensation is structured so that the outside vendor performs most of the services and the pain practice bills the services and keeps a percentage of the allowable. I have always been concerned about these arrangements as potentially violating the kickback statute because the pain practice is arguably referring the patient to a

New Final Rule and Revised NPP Template. On February 13, 2026, the Office of Civil Rights ("OCR"), which is the entity that enforces HIPAA, issued a new Final Rule for the confidentiality of SUD (substance use disorder) patients, along with a revised template for your required Notice of Privacy Practices ("NPP"). The revised NPP amends the prior NPP template and incorporates required verbiage about the confidentiality of SUD records. NPP Problems for Anesthesia Groups.

In 2025, Medicare bundled certain thoracic fascial plane blocks into many of the anesthesia codes with the NCCI showing a modifier of "0" (meaning that those blocks could not be billed even with modifier 59 or XU). Now, as of 1/1/26, most (but not all) of those bundling edits have been reversed. The January version of the NCCI edits reveals the following: 64468 and 64469  (bilateral thoracic fascial plane blocks) were previously bundled with 00470, 00472, 00474, 00500, 0052

Effective for dates of service on or after January 15, 2026, CMS is starting the WISeR (Wasteful and Inappropriate Service Reduction) model in 6 states where prior authorizations are required for 14 different surgical and/or procedural services, which will affect both anesthesia and chronic pain providers in those states.  If an approval is not obtained prior to performing the procedure, Medicare will not pay for the service until a prepayment review is performed.  If the pre

On November 12, 2025, President Trump signed a Continuing Resolution (“CR”) that ended the government shutdown, and among other things, extended the telehealth flexibilities through January 30, 2026.  This week CMS published updated Telehealth FAQs in which the following was confirmed: 1.     Patient Residence and Location .   Through January 30, 2026, Medicare beneficiaries do not have to live in rural areas or be present in a facility when receiving telehealth services.  In

On October 31, 2025, Medicare released the 2026 Final Rule for the Physician's Fee Schedule, which contains the new Medicare changes being implemented next year. Here are the highlights insofar as they affect anesthesia and chronic pain. Most of the changes relates to chronic pain. 1.     Conversion Factors (“CFs”).   Beginning in 2026, there are 2 CFs for anesthesia and non-anesthesia codes.  One CF is for providers participating in an “alternative payment model” (“APM”),

Just a reminder that the Medicare COVID telehealth flexibilities are set to expire at the end of this month if not extended by Congress...