The credentialing case log, what hospitals actually ask for.

Who sets the numbers: your hospital

There is no national case count for anesthesia privileges. Medicare’s rules for hospitals require the medical staff to “examine the credentials of all eligible candidates” and require the bylaws to include “criteria for determining the privileges to be granted,” but they leave the criteria themselves to each hospital.

42 CFR 482.22(a)(2) and (c)(6), Condition of participation: Medical staff.

The American Society of Anesthesiologists says the same thing from the other side. Its statement on privileges in anesthesiology lists the criteria an organization might use, then says “Organizations should determine which criteria to include,” adding any others the institution requires. It sets no case counts, including for transesophageal echocardiography, where it lists the NBE’s Advanced PTEeXAM as a possible criterion.

ASA, Statement on Delineation of Clinical Privileges in Anesthesiology, last amended October 18, 2023.

For CRNAs: what you personally performed

ASA’s statement on privileges for nurse anesthetists and anesthesiologist assistants is more specific about documentation. For initial privileges it calls for:

• “Documentation of tasks personally performed (not tasks observed)”
• “Quantitative assessment of tasks personally performed within the past two years”
• For a task without formal training, documentation of it done under physician supervision “with an appropriate quantitative threshold to ensure competency”

For keeping privileges, it asks for “objective measures of task performance and outcomes” with quantitative and qualitative assessment. The threshold itself is, again, the institution’s.

ASA, Statement on Clinical Privileges for the Non-Physician Anesthesia Provider, approved October 18, 2023.

The words “personally performed” and “the past two years” are the practical part: a log that records each case you did, dated, and can be cut to any two-year window answers both.

Reappointment, and the evaluations in between

• Every two or three years. Since February 19, 2023, The Joint Commission has allowed privileges to run up to three years, or a shorter period when law requires. Some states still require two (California’s Title 22 does), so your hospital’s cycle may not have changed.
• Medicare doesn’t set the interval. Its rule is that the medical staff “must periodically conduct appraisals of its members.”
• Evaluations between reappointments. Joint Commission hospitals also run ongoing professional practice evaluation (OPPE), and focused evaluation (FPPE) for new privileges. Each medical staff decides what data goes into them, and case volume is often part of it.

The Joint Commission, MS.06.01.07 EP 9, as reported by Barrins & Associates; Polsinelli, “Title 22 is Governing Law in California” (2023); 42 CFR 482.22(a)(1).

What the boards don’t ask for

A case log is a hospital’s question, not a certifying board’s:

ABA, Continuing Certification (MOCA); NBCRNA, Continued Professional Certification program page; NBE, Advanced PTEeXAM certification. The NBE’s numbers and rules are on our cardiothoracic requirements page.

Directing, supervising, independent: the model on each case

For Medicare, an anesthesiologist is “medically directing” a case only when, for that patient, they meet seven conditions: a pre-anesthetic exam, prescribing the plan, personally participating in the most demanding parts including induction and emergence where applicable, making sure a qualified person does the rest, monitoring at frequent intervals, staying physically present for emergencies, and providing post-anesthesia care. They may direct no more than four concurrent cases, and the physician alone documents that the conditions were met.

42 CFR 415.110(a) and (b).

When those conditions aren’t met, or there are more than four concurrent cases, the service is billed as medical supervision instead, which is paid differently. Medicare contractors use these modifiers:

Novitas Solutions (Medicare Administrative Contractor), Anesthesia Modifiers. Medically directed services are paid at 50 percent of the personally performed rate, per the same page.

Don’t confuse this with the other “supervision” in Medicare’s rules. The hospital condition of participation has a CRNA work under the supervision of the operating practitioner or of “an anesthesiologist who is immediately available if needed,” unless the state’s governor has opted out. That one is about who may give anesthesia, not about payment.

42 CFR 482.52(a)(4) and (c).

Why it belongs in a case log: committees and practice-capacity questions ask how you worked, not just what you did, and the honest answer is per case. Your case log is your own record, though. The anesthesia record and your group’s billing documentation are what count for payment and compliance.

Keep patient identifiers out

A case log for credentialing needs counts and categories, not patients. HIPAA’s de-identification standard lists 18 kinds of identifiers, among them names, any address detail smaller than a state, all dates except the year that relate to the patient (birth, admission, procedure), and ages over 89, which it says may be grouped as “age 90 or older.” Medical record numbers are on the list too.

45 CFR 164.514(b)(2)(i).

A running case number you assign yourself, the procedure, the ASA class, an age band and the facility give a committee everything it asks for.

Keeping it ready

None of this is a rule; it’s what makes the request painless when it comes:

• Log the same day. A case reconstructed from memory a year later is a guess.
• Record the facility. Privileges are granted facility by facility, and committees ask where your cases were.
• Record your model on every case: solo, directing or supervising; or for CRNAs, independent, medically directed or medically supervised.
• Keep the categories committees count: ASA class and emergencies, age bands, specialty, technique.
• Be able to cut any date range, since a committee may ask for the last two years, or for the cases since your last reappointment.