Anesthesia Medical Direction Attestation (CMS 7 Requirements)
A compliance attestation template for physician anesthesiologists documenting fulfillment of the seven CMS-required activities when medically directing CRNAs, AAs, or residents. Supports care-team billing with structured…
Document Type
form / Checklist Or Bundle Compliance Form
Specialties
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(This attestation must be authored by the medically directing physician for a specific case. Populate all fields from the anesthesia record and related documentation.)
Patient Name: [Patient name]
MRN: [Medical record number]
Date of Service: [Date]
Facility/Location: [Facility and location]
Procedure: [Procedure name]
Surgeon: [Surgeon name]
Anesthesia Type: [GA / MAC / regional / neuraxial]
Anesthesia Start Time: [Start time]
Anesthesia End Time: [End time]
Medically Directing Physician: [Physician name, credentials]
Medically Directed Clinician(s):
- [Name], [Credential] ([Time segment covered])
- (Add additional clinicians as needed with their time segments)
Attestation Statement
I personally medically directed the anesthesia care for this patient and fulfilled all required physician activities for medical direction, as detailed below and/or as documented in the referenced sections of the anesthesia record.
Required Elements for Medical Direction
1. Pre-Anesthetic Examination and Evaluation
Completion: [Personally performed / Performed by another group physician]
Performing Physician (if different from directing physician): [Name, credentials]
Time completed: [Timestamp]
Documentation reference: [Pre-anesthesia evaluation note / H&P / Anesthesia pre-op note]
2. Anesthesia Plan Prescribed
Plan prescribed by physician anesthesiologist: [Yes]
Documentation reference: [Pre-anesthesia evaluation note / Anesthesia plan section]
Material intraoperative deviations from plan: [None / Describe deviation, rationale, and time]
3. Participation in Most Demanding Aspects
(Include only the subsection relevant to the anesthesia type.)
General Anesthesia (if applicable):
- Induction: [Present] at [Time]; Reference: [Anesthesia record / Note location]
- Emergence/Extubation: [Present] at [Time]; Reference: [Anesthesia record / Note location]
MAC / Regional / Neuraxial (if applicable):
- Most demanding aspect(s): [e.g., initiation of sedation, airway-risk period, block placement]
- Physician presence: [Present] at [Time]; Reference: [Anesthesia record / Note location]
4. Qualified Individuals Performed Delegated Procedures
Delegated components performed by qualified, credentialed personnel: [Yes]
Clinician(s) and coverage periods:
- [Name], [Credential], Coverage: [Start–End time]
- (List relief/break coverage with time segments as applicable)
5. Monitored at Frequent Intervals
Physician monitored course at frequent intervals: [Yes]
Evidence of monitoring: [Timestamped checks / Physician entries on anesthesia record / Intraoperative notes]
- [Time]: [Brief status or interaction] (Reference: [Anesthesia record / Intraop note])
- (Include at least one documented intraoperative monitoring point beyond induction/emergence for longer cases)
6. Immediately Available Throughout
Immediate availability maintained throughout: [Yes / No—see details below]
If any departure from immediate availability occurred:
- Reason: [Reason for departure]
- Duration: [Start time – End time]
- Covering physician: [Name, credentials / N/A]
- Medical direction criteria maintained: [Yes / No] (If no, do not complete this attestation; route to billing/compliance.)
7. Post-Anesthesia Care Provided
Post-anesthesia evaluation time: [Time]
Summary of findings: [Airway/respiratory status, hemodynamics, pain, nausea, mental status]
Interventions: [None / Description of interventions]
Disposition: [PACU / ICU / Floor / Home / Other]
Documentation reference: [PACU note / Post-anesthesia evaluation note / Anesthesia record]
Concurrency Statement
Maximum concurrent medically directed cases during this case: [1 / 2 / 3 / 4]
Services performed that would diminish scope of control: [None / Describe]
Concurrent interruptible activities (if any): [None / Activity description with times]
(If any required element above cannot be truthfully attested, do not complete this attestation. Document actual events and route to billing/compliance for appropriate billing pathway determination.)
Physician Signature: [Electronic signature / Name, credentials]
Date/Time of Attestation: [Timestamp]
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