A Distinction with a Difference
Taking a deep dive into the distinction between CRNAs providing anesthesia under “medical direction” versus under “medical supervision,” the United States Court of Appeals for the Ninth Circuit affirmed the dismissal of a qui tam action in a case brought by a relator under the False Claims Act, holding that the complaint failed to plausibly allege that the anesthesia LLC had submitted false claims by using the QZ billing modifier for anesthesia services provided by a CRNA. U.S. ex rel. O’Neill v. Somnia, Inc. et al.
