The 27 states where CRNAs can practise without physician supervision

By the Titrate Revenue team · Clinical review by Nelson L., CRNA · Updated October 2026

What opting out means

Opting out removes the federal Medicare supervision requirement in that state. State law, facility rules and payer contracts still apply, so a CRNA group's setup should be checked state by state.

Why it matters for billing

In opt-out states, CRNAs working without medical direction can bill Medicare in their own right using the QZ modifier, which makes accurate billing central to an independent group's income.

This article is general information, not billing, legal or tax advice. Payer rules change; always check current guidance.

Sources

• Becker's ASC Review: The 27 states where CRNAs don't need physician supervision (September 2026)