A recent OIG audit found that a Medicare Administrative Contractor (MAC) paid physicians for anesthesia services administered during facet joint injection sessions—even when documentation did not support medical necessity. The report estimates Medicare could have saved $177 million if oversight had prevented at-risk payments related to anesthesia during spinal pain management procedures.

What’s the Issue?

Local Coverage Determinations (LCDs) for both epidural steroid injections (ESIs) and facet joint injections clearly state that moderate sedation, deep sedation, general anesthesia, or Monitored Anesthesia Care (MAC) is usually unnecessary for these procedures.

Despite this, anesthesia services were billed and paid without documentation reflecting why sedation or anesthesia was required.

Why This Matters

For coding, billing, and compliance teams, this is a significant watch point:

• Anesthesia must be medically necessary and documented

• Routine use of MAC or deeper sedation for spinal pain injections may trigger audit scrutiny

• MACs and CMS oversight activity are increasing in this area

Final Takeaway

Organizations performing ESIs or facet joint injections should review documentation standards, ensure providers understand LCD requirements, and consider proactive internal audits. With OIG attention now on this issue, anesthesia billing in pain management procedures is clearly on the compliance radar.

📖 Sources: OIG Report (2025); Novitas Medicare News Update