Coding errors
Anesthesia time billed in excess of documented minutes
Anesthesia is one of the few services billed by the minute. The formula: (base units for the case) + (time units = total minutes ÷ 15) × the conversion factor. Anesthesia time runs from the moment the anesthetist starts preparing the patient to when they hand off post-recovery. The exact start and stop are documented in the anesthesia record, which the patient can request.
Federal basis
ASA Relative Value Guide + CMS billing guidance
CMS Internet Only Manual Pub. 100-04, Ch. 12 §50
Read the source →What this looks like in practice
Anesthesia time billing has a well-defined federal standard. The American Society of Anesthesiologists publishes the Relative Value Guide; CMS uses it as the reference. The anesthesia record (separate from the surgeon's operative note) documents start time, stop time, and a continuous record of vitals/medications during the case. That record is in the medical chart and accessible under HIPAA §164.524.
The pattern that gets audited: anesthesia time on the bill exceeds the documented start-stop in the record. Sometimes by a small amount (rounding up), sometimes substantially (15-30 minutes). A 30-minute over-bill at typical conversion rates is a few hundred dollars per case. OIG has issued multiple audit reports on this in different specialties.
How to spot it on a bill
- 01.Bill includes anesthesia time units; the math (units × 15 min) yields a number larger than the actual operating-room or procedure-room duration.
- 02.The anesthesia record (request via HIPAA) shows different start/stop times than the bill reflects.
- 03.Procedure that's typically 60 minutes was billed for 90+ minutes of anesthesia.
What to write — ready-to-paste language
Replace the bracketed fields with your specific details. Send by certified mail with return receipt, or via the hospital’s patient portal if it offers documented messaging. Keep a copy.
I'm requesting an anesthesia time review for the procedure on [date] at [facility]. The bill reflects [N] anesthesia time units, which equates to [N×15] minutes of anesthesia time. Per the anesthesia record (which I have requested via HIPAA §164.524), please confirm the documented anesthesia start and stop times. If the documented time is shorter than what was billed, please recalculate the time units and adjust the bill. The standard reference for time-unit calculation is the ASA Relative Value Guide and CMS Pub. 100-04 Ch. 12 §50.
This is a starting point, not legal advice. Your specific situation may warrant additional details. Our scan tool drafts this letter automatically with your bill’s specifics filled in.
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Related scenarios
Upcoded ER visit — when the level on the bill doesn't match the chart
ER visits billed at a higher complexity level than the medical record supports are the most common billing-error pattern in the country. Federal coding rules let you dispute the level.
Unbundled charges — when one procedure gets billed as several
Federal coding rules (NCCI edits) explicitly prohibit billing certain combinations of CPT codes together. When you see them on your bill, the federal benchmark gives you grounds to dispute.
Wrong place-of-service code — facility billing for a non-facility visit
Place-of-service codes determine whether Medicare and most insurance pay the higher facility rate or the lower non-facility rate. A code mismatch can inflate a bill substantially.
Modifier-25 abuse — separate E/M billed alongside a procedure
Modifier 25 lets a provider bill an office visit alongside a procedure on the same day, but only when the visit is a 'significant, separately identifiable' service. The OIG has repeatedly flagged inappropriate use.
Common questions
How do I get the anesthesia record?
What's a 'unit' in anesthesia billing?
P.S. The dispute language above is a starting point. Bills with this pattern often have additional issues alongside it — coding errors stacked with markup, surprise bills stacked with charity- care eligibility. The scan finds all of them in one pass. Start the audit →
P.P.S.Federal law gives you these rights regardless of how the bill arrived. Insured, uninsured, in-network, out-of-network — the underlying patient-protection statutes apply.
P.P.P.S. Bills are time-sensitive. Most insurance appeals must be filed within 180 days. Charity-care discounts at non-profit hospitals are most easily applied within 240 days of the original bill. Acting earlier costs less.