CO-194: Anesthesia by Operating/Attending Physician
Anesthesia performed by the operating physician, the assistant surgeon, or the attending physician. Payment is adjusted because the anesthesia was provided by the surgeon or attending rather than a separate anesthesiologist.
Why Claims Get Denied with CO-194
Denial code CO-194 is triggered when anesthesia performed by the operating physician, the assistant surgeon, or the attending physician. payment is adjusted because the anesthesia was provided by the surgeon or attending rather than a separate anesthesiologist. Understanding the root causes helps prevent future denials and strengthens your appeal when one occurs.
Surgeon administered their own anesthesia (local or regional)
Anesthesia billed separately when it is included in the surgical procedure
Attending physician provided anesthesia without a separate anesthesiologist
Incorrect billing of anesthesia services by the operating provider
How to Appeal CO-194
If a separate anesthesiologist provided the anesthesia, provide documentation including the anesthesia record showing a distinct provider. If the surgeon administered local anesthesia that is typically bundled, the adjustment may be correct. Verify proper use of anesthesia modifiers (AA, QK, QX, QY, QZ).
Documentation Required for Appeal
A successful appeal of CO-194 requires thorough documentation. Gather these items before drafting your appeal letter:
Anesthesia record showing the administering provider
Operative report documenting anesthesia type
Separate anesthesiologist's notes (if applicable)
Correct anesthesia modifier documentation
How to Prevent CO-194 Denials
Verify anesthesia billing rules when the surgeon provides their own anesthesia. Use correct anesthesia modifiers to reflect who administered the anesthesia. Ensure separate anesthesia services are documented with distinct provider records.
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