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Allowing a student enrolled in a nurse anesthesia graduate degree program (“Student Registered Nurse Anesthetist” - SRNA) to administer anesthesia in a hospital setting without the continuous physical presence of a qualified and credentialed anesthesiologist or anesthetist violates federal regulations in most circumstances. This practice places both the anesthesia staff and the hospital in violation of the Centers for Medicare & Medicaid Services (CMS) Hospital Conditions of Participation (COP).
The CMS COPs establish the minimum health, safety, and operational standards that healthcare organizations must meet to participate in the Medicare and Medicaid programs. These requirements are outlined in Title 42 of the Code of Federal Regulations. Failing to meet, or intentionally violating, the COPs may result in unsafe patient care, charges of submitting false claims, and the revocation of access to federal payments.
The CMS COPs are both specific and restrictive regarding the qualifications of the licensed health care professionals that may administer anesthesia in a hospital setting 1,2:
From - §482.52(a) Conditions of Participation: Anesthesia services, Section a: Standard: Organization and staffing; and § 410.69: Services of a certified registered nurse anesthetist or an anesthesiologist's assistant: Basic rule and definitions.
Anesthesia must be administered only by
CMS also dictates that an individual who is qualified to administer anesthesia may only do so in a hospital setting if they have been granted the required institutional privileges3. The individual’s anesthesia privileges must have been recommended by the medical staff organization and approved by the hospital’s governing body.
The environment of care in which SRNAs complete their education must comply with these federal mandates. While participating in a hospital-based clinical education program, an SRNA is limited to assisting a qualified anesthesia professional who has been granted the necessary anesthesia privileges, who is continuously physically present, and who maintains direct responsibility for the administration of anesthesia4.
Federal regulations also limit Medicare Part B anesthesia payments to specific categories of clinicians. For the purposes of anesthesia services claims, the clinician must be a physician, CRNA, or CAA5. Claims may never be submitted for services provided by an SRNA.
Certain non-hospital settings and federally designated rural Critical Access Hospitals do permit anesthesiologists and CRNAs to claim partial payment when supervising SRNA-administered anesthesia in these locations6,7,8. Payment limitations are detailed in the Medicare Claims Processing Manual, Chapter 12, sections 50(C) and 140.55. Nonetheless, even in these limited situations anesthesia services must comply with applicable State Board of Health regulations for licensed healthcare facilities, state Nursing Board scope of practice regulations, and medical staff bylaws governing the administration of anesthesia within the facility.
Accrediting organizations as well as federal and state agencies may survey a hospital and its anesthesia group according to the COP and billing requirements outlined above.
Date of last update: August 4, 2026
You do not have to make a payment at this time, but you can reach out to your practice/group leader to find out when they plan to pay your dues. Email or call the ASA Support team for assistance: (630) 912-2552 or info@asahq.org.
