A Blueprint for Success: Implementation of the Center for Medicare and Medicaid Services Mandated Anesthesiology Oversight for Procedural Sedation in a Large Health System

In 2009, the Center for Medicare and Medicaid Services (CMS) issued the §482.52 Condition of Participation (CoP) that the director of anesthesia services (DAS) is responsible for all anesthesia administered in the hospital, including moderate and deep procedural sedation provided by nonanesthesiologists. Although this mandate was issued several years ago, many anesthesiology departments remain uncertain as to how best to implement it, who needs to be involved, what resources are needed, and how to leverage this oversight to improve quality of care and patient safety. This article reviews the CMS CoP interpretive guidelines and other regulations as they relate to procedural sedation, outlines the components and benefits of anesthesiology oversight, and describes the tools and structure to implement these guidelines. In addition, we discuss some of the challenges surrounding this implementation. This initiative continues to evolve and expand as needs change and experience develops.