​In collaboration with the California BRN, this AFL clarifies CRNA credentialing and privileging requirements for GACHs providing anesthesia services. CRNAs may administer anesthesia services when meeting state and federal requirements outlined below.​

State Requirements

For GACHs using CRNAs to provide anesthesia services, all of the following must be met:

• A CRNA must be a registered nurse licensed by the California Board of Registered Nursing (BRN) who has met standards for certification from the BRN. (BPC section 2826)

• Use of CRNAs to provide anesthesia services in an acute care facility must be approved by the hospital administration and the appropriate committee and must be at the discretion of the physician, dentist, or podiatrist. (BPC section 2827)
• A CRNA may only administer anesthesia and anesthesia related medications ordered by a physician, dentist, podiatrist, or clinical psychologist. (BPC section 2725)
• Except as provided in BPC section 2725, a CRNA is not authorized to practice medicine or surgery. (BPC section 2833.5)
• The general scope of practice for CRNAs is governed by the Nursing Practice Act (BPC section 2700, et seq.) and regulated by the BRN.
• The GACH's Committee on Interdisciplinary Practice is responsible for recommending policies and procedures for the granting of expanded role privileges to registered nurses, whether or not employed by the facility, to provide for the assessment, planning, and direction of the diagnostic and therapeutic care of patients. (Title 22 section 70706.1)
• The Committee on Interdisciplinary Practice is responsible for reviewing credentials and making recommendations for the granting or rescinding of nonphysician privileges. (Title 22 section 70706.1)
• Written policies and procedures regarding anesthesia service shall be developed and maintained by the person responsible for the service in consultation with other appropriate health professionals and administration and shall be approved by the governing body. These policies and procedures shall include defining the responsibility and accountability of the anesthesia service to the medical staff and administration. In part, the policies and procedures must include provision for “[p]reanesthesia evaluation of the patient by an individual qualified to administer anesthesia as a licensed practitioner in accordance with his or her scope of licensure."  (Title 22 section 70233)
• A CRNA who is not employed directly by a GACH but provides anesthesia services in a GACH must be subject to the bylaws of the facility and may be required by the GACH to provide proof of current professional liability insurance coverage. (BPC section 2828)
• A CRNA must be responsible for their own professional conduct and may be held liable for those professional acts. (BPC section 2828)
  

In California, a CRNA administering anesthesia services is not required to be under the supervision of the operating practitioner or of an anesthesiologist, however they may only provide services within their scope of practice. “It is the Nursing Practice Act that gives CRNA's legal authority to administer anesthesia after a physician orders a course of treatment that includes anesthesia." (California Soc'y of Anesthesiologists v. Superior Court; see also BPC section 2725) ​

Federal Requirements

In addition to the state requirements, certified GACHs using CRNAs to provide anesthesia services must meet the following federal requirements:

• A CRNA must meet the following credentialing criteria (Title 42 CFR section 410.69):
• Pass a certification examination of the Council on Certification of Nurse Anesthetists, the Council on Recertification of Nurse Anesthetists, or any other certification organization that may be designated by the Secretary,
  OR
• Be a graduate from a nurse anesthesia educational program that meets the standards of the Council on Accreditation of Nurse Anesthesia Programs, or such other accreditation organization as may be designated by the Secretary, and pass a certification examination of the Council on Certification of Nurse Anesthetists, the Council on Recertification of Nurse Anesthetists, or any other certification organization that may be designated by the Secretary within 24 months of graduating.
• If a GACH furnishes anesthesia services, the GACH's policies and procedures on anesthesia services must include the delineation of pre-anesthesia and post-anesthesia responsibilities “by an individual qualified to administer anesthesia." (Title 42 CFR section 482.52(b))
• If a GACH furnishes anesthesia services, they must be provided in a well-organized manner under the direction of a qualified doctor of medicine or osteopathy. The service is responsible for all anesthesia administered in the hospital. (Title 42 CFR section 482.52)
• A CRNA providing anesthesia services may review and verify (sign and date), rather than re-document, notes in a patient's medical record made by physicians, residents, nurses, medical, physician assistant, advanced practice registered nurse students, or other members of the medical team, including, as applicable, notes documenting the CRNA's presence and participation in the service. (Title 42 CFR section 410.69)​
  

CRNA Scope of Practice

For additional information on scope and standards of practice for CRNAs, please see the BRN's Summary of Select Nursing Practice Act Provisions Relating to CRNA Practice (PDF) and CRNA homepage.

If you have questions:

• For CRNA scope of practice, contact: BRN through the BRN's Contact Us webpage.
• For hospital requirements, contact: your local district office.
  

Sincerely,

Original signed by Cassie Dunham

Cassie Dunham

Deputy Director​​