CARC 194 Active

CO-194: Anesthesia by Operating/Assistant/Attending Physician

TL;DR

Verify a separate anesthesia provider performed the service. Correct provider information and modifiers, then resubmit.

Action

Verify & Resubmit

Who Pays

Provider

Appeal

Yes

Patient Impact

None

Disclaimer

This content is for informational purposes only and does not constitute professional billing advice. Always verify information against your payer contracts and current coding guidelines. Consult a certified billing specialist for specific claim issues.

What Does CO-194 Mean?

With CO (Contractual Obligation), the anesthesia is bundled into the surgical payment as a contractual matter. If a separate anesthesia provider performed the service, correct the claim and resubmit with the proper provider identification. If the surgeon provided the anesthesia, the payment is typically included in the surgical fee.

CARC 194 indicates that anesthesia services were billed separately but the payer determined they were performed by the operating physician, assistant surgeon, or attending physician rather than a dedicated anesthesia provider (anesthesiologist or CRNA). Most payers consider anesthesia by the surgeon to be included in the surgical payment and do not pay for it separately.

This code commonly appears when anesthesia claims are submitted without proper provider identification or modifiers to distinguish who administered the anesthesia. If a separate anesthesia provider (anesthesiologist or CRNA) actually performed the anesthesia, the claim needs to be corrected with the appropriate provider information and modifiers.

Common Causes

Cause	Frequency
Anesthesia billed separately by the operating surgeon The operating surgeon billed for anesthesia services in addition to the surgical procedure, and the payer considers anesthesia by the surgeon as included in the surgical payment or denied	Most Common
Assistant surgeon billed for anesthesia services The assistant surgeon billed for anesthesia services, which is not recognized as a separately payable service when performed by the assistant surgeon	Common
Attending physician billed anesthesia during own procedure The attending physician who is also performing or supervising the procedure billed separately for anesthesia services	Common
Incorrect modifier indicating separate anesthesia provider The claim was submitted without proper modifiers indicating that a separate anesthesia provider was not involved, or the modifiers incorrectly suggest the operating physician provided anesthesia	Common

How to Resolve

Confirm the anesthesia provider Verify whether a separate anesthesiologist or CRNA performed the anesthesia.
Correct the claim If a separate provider was involved, update the NPI and modifier information.
Review modifier 47 rules If the surgeon administered the anesthesia, check if the payer allows modifier 47 for separate payment.
Resubmit Submit the corrected claim with accurate provider and modifier information.

Appeal Guide

Appeal with documentation showing the anesthesia was performed by a separate qualified anesthesia provider (anesthesiologist or CRNA), including the anesthesia record, provider identification, and appropriate modifiers.

Common RARC Pairings

The RARC code tells you exactly what triggered the CO-194:

RARC	Description
N130	You may need to review plan documents or guidelines Review the payer's anesthesia billing guidelines for operating physician scenarios →
N381	Consult your contractual agreement Check contract terms regarding anesthesia billing when performed by the operating or attending physician →

How to Prevent CO-194

Ensure anesthesia claims accurately identify the provider who administered the anesthesia
Use correct modifiers to distinguish between anesthesia provided by a separate provider versus the operating surgeon
When the surgeon provides their own anesthesia, use modifier 47 (Anesthesia by Surgeon) if applicable per payer guidelines
Verify payer-specific rules for anesthesia billing when the operating physician is involved
Train billing staff on proper anesthesia billing coding and provider identification requirements

Also Filed As

The same CARC 194 may appear with different Group Codes:

OA-194 PR-194

Related Denial Codes

CO-144 — Incentive Adjustment for Preferred Product/Service CO-147 — Provider Accepted Reduced Payment from Regulatory Authority CO-155 — Patient Refused the Service/Procedure CO-160 — Benefit Exclusion: Injury from Excluded Activity CO-161 — Provider Performance Bonus

Sources

https://www.mdclarity.com/denial-code-carcs
https://x12.org/codes/claim-adjustment-reason-codes
https://portal.ct.gov/-/media/ohs/health-it-advisory-council/apcd-advisory-group/data-submission-guide-workgroup/meeting-materials/6-30-22/carc-codes_final.pdf
https://medicaid-documents.dhhs.utah.gov/Documents/pdfs/ClaimDenialCodes.pdf
Codes maintained by X12. Visit x12.org for official definitions.