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

What Does OA-194 Mean?

OA-194 may appear in coordination of benefits situations where the anesthesia bundling adjustment is being passed between payers. The primary payer denied the anesthesia as bundled, and the secondary payer is acknowledging the same determination in their adjudication.

CARC 194 appears when a payer determines that anesthesia services were provided by the same physician who performed the surgery, assisted in the surgery, or served as the attending physician — and the payer does not reimburse anesthesia separately in that scenario. The payer considers the anesthesia component to be included in the surgical or procedural payment, not a standalone billable service.

This code is most commonly seen in ambulatory surgery settings or smaller practices where the operating surgeon personally administers local or regional anesthesia rather than involving a separate anesthesiologist or CRNA. While some payers allow separate billing for surgeon-administered anesthesia using modifier 47, others have blanket policies that deny it regardless of modifiers. The key is understanding the specific payer's stance on physician-administered anesthesia before the claim is submitted.

The financial impact of CARC 194 falls primarily on the provider under CO. The payer treats this as a bundling issue — the anesthesia is considered part of the surgical global package. Providers who routinely administer their own anesthesia should verify each payer's policy and ensure their charge capture process correctly handles these scenarios to avoid systematic denials.

How to Resolve

Verify the payer's anesthesia billing policy, apply correct modifiers, and resubmit if separate billing is allowed — otherwise, accept the bundling adjustment.

1. Review primary payer adjudication Check the primary payer's ERA to understand the basis for the bundling denial and whether it applies at the secondary payer level as well.
2. Submit to secondary payer with documentation Forward the claim to the secondary payer with the primary remittance. Some secondary payers may have different anesthesia billing rules.
3. Accept the adjustment if both payers bundle If both payers deny separate anesthesia reimbursement, post the write-off and update your records.

How to Prevent OA-194

• Verify anesthesia billing policies for all payers in a patient's coverage chain before submitting claims
• Coordinate charge capture for anesthesia services across primary and secondary billing workflows

Also Filed As

The same CARC 194 may appear with different Group Codes:

Related Denial Codes