Billing for SPRAVATO

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AD04

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Anyone here with SPRAVATO experience? How did you bill (E/M) when checking up on the patient after administration?

I'm thinkin 99215 as this is for treatment resistant depression and requires a medication with extensive monitoring.

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I bill by time—120 min as I monitor the whole time by video from my office.
 
We have a pretty busy esketamine service. We typically bill 99214 + 99415 for each visit. Sometimes 99215 is appropriate if things are going south clinically or you spend more time speaking with them than usual. The actual assessments with the MDs in our program is usually pretty brief, though.
 
We have a pretty busy esketamine service. We typically bill 99214 + 99415 for each visit. Sometimes 99215 is appropriate if things are going south clinically or you spend more time speaking with them than usual. The actual assessments with the MDs in our program is usually pretty brief, though.

This makes sense and I'll follow this when I bill. My interactions will be brief as well as I have nurses who can monitor patients for 2 hours while I attend to other patients.
 
It was my understanding that the patients had to be monitored in a healthcare setting while taking it. Wouldn't that be dispensing and not prescribing?

Dispensing is a term used for clinics/offices that have a pharmacy and provide take-home meds. Spravato with REMS goes through the pharmacy process at a specialty pharmacy or with the insurance company pre-receiving it. It is patient administered in clinic. Clinics merely receive and monitor use.

Spravato loses money or at best is utilizing under-utilized space. Monitoring and documenting in an office for 2 hours by a technician is a waste of space with little reimbursement. Getting it approved takes tons of staff time. If you buy and bill with pre-approval that is later denied can result with you being stuck with the bill.
 
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Dispensing is a term used for clinics/offices that have a pharmacy and provide take-home meds. Spravato with REMS goes through the pharmacy process at a specialty pharmacy or with the insurance company pre-receiving it. It is patient administered in clinic. Clinics merely receive and monitor use.

Spravato loses money or at best is utilizing under-utilized space. Monitoring and documenting in an office for 2 hours by a technician is a waste of space with little reimbursement. Getting it approved takes tons of staff time. If you buy and bill with pre-approval that is later denied can result with you being stuck with the bill.

I begin to understand why the local cowboys just order ketamine nasal sprays at compounding pharmacies instead.
 
Dispensing is a term used for clinics/offices that have a pharmacy and provide take-home meds. Spravato with REMS goes through the pharmacy process at a specialty pharmacy or with the insurance company pre-receiving it. It is patient administered in clinic. Clinics merely receive and monitor use.

Spravato loses money or at best is utilizing under-utilized space. Monitoring and documenting in an office for 2 hours by a technician is a waste of space with little reimbursement. Getting it approved takes tons of staff time. If you buy and bill with pre-approval that is later denied can result with you being stuck with the bill.
Completely agree.
 
I begin to understand why the local cowboys just order ketamine nasal sprays at compounding pharmacies instead.
It's not just the cowboys, huge organizations running residential treatment centers across the country are getting it compounded instead.
 
Any updates on reimbursement for spravato from insurances? Is it still just a normal clinic visit coding that you would bill based off of? Is there no procedural code for this?

There are several clinics in my area & also in the Midwest billing 99215 + 99417 (x4) per patient, per treatment. Comes out to 5.28 wRVU each treatment. Most places do 4-6 patients at a time. Physician must be physically present in the room for ~1hr 15 min to bill for the full 2 hours. This is for private insurance and must be a "provider based outpatient clinic."

Medicare is 99215 + G2212 (x3). Comes out to about 4.6 wRVU/treatment.

Swimming in wRVUs.
 
There are several clinics in my area & also in the Midwest billing 99215 + 99417 (x4) per patient, per treatment. Comes out to 5.28 wRVU each treatment. Most places do 4-6 patients at a time. Physician must be physically present in the room for ~1hr 15 min to bill for the full 2 hours. This is for private insurance and must be a "provider based outpatient clinic."

Medicare is 99215 + G2212 (x3). Comes out to about 4.6 wRVU/treatment.

Swimming in wRVUs.
Have you seen these setups? Is the doc able to see each patient individually while also counting as being present for the other 3-5 patients?
 
Have you seen these setups? Is the doc able to see each patient individually while also counting as being present for the other 3-5 patients?

I’d be worried about this too. You can bill extended time without actually seeing the patient during that time? So if I have some rating scales, UDS, and other office things, I can bill for extended time while this happens?
 
I’d be worried about this too. You can bill extended time without actually seeing the patient during that time? So if I have some rating scales, UDS, and other office things, I can bill for extended time while this happens?
I love the idea behind the 2021 changes to billing but I am very worried about abuse. Can I just sit in an office with 1-way glass mirror overlooking my waiting room and count every patient in there completing any paperwork or doing anything as minutes on day of the encounter while meeting another patient? Because if the Spravato billing above works like this, I can't see why mine wouldn't as well. I am already seeing other doctors greatly inflate their time spent on day of visit (in other specialties).
 
I love the idea behind the 2021 changes to billing but I am very worried about abuse. Can I just sit in an office with 1-way glass mirror overlooking my waiting room and count every patient in there completing any paperwork or doing anything as minutes on day of the encounter while meeting another patient? Because if the Spravato billing above works like this, I can't see why mine wouldn't as well. I am already seeing other doctors greatly inflate their time spent on day of visit (in other specialties).

Yeah I feel like insurance is gonna catch on to this at some point. You're not billing some kind of group/group therapy code. You're billing 4-6 individual notes/codes that are all occurring during the same time. Doesn't seem like it's gonna pass muster.

I figured the time inflation thing would start happening. Start billing every patient for a 99214 saying they spent 10 minutes seeing the patient and 20 minutes documenting.
 
Have you seen these setups? Is the doc able to see each patient individually while also counting as being present for the other 3-5 patients?

Yes. The physician is physically present in the room sitting at a computer doing notes. The patients are all sitting in the same room, separated by individual partitions. He can view all of them throughout the 2-hour process. They have an iPad in front of them where they fill out a HAM-D and MADRS before the treatment. Then they sit in their comfy chairs doing whatever they like for the next two hours (i.e. listen to music, relax with eye masks, etc).
 
We are still billing 99214/99215 (depending on the severity of symptoms + 99417 x 1 for our Spravato visits. The post-administering monitoring is done by a medical assistant - not the physician - in our clinic and we haven't had any difficulty getting these codes reimbursed thus far. We also document explicitly in our treatment notes that supervision is being done by the medical assistant and that the treating physician was immediately available in the clinic, if needed (which is true).

While it may be a bit sketchy, I don't see any problem with billing monitoring codes for multiple patients at the same time. It's entirely feasible to observe multiple patients at once, as others have mentioned, depending in the physical layout of your space.
 
Yes. The physician is physically present in the room sitting at a computer doing notes. The patients are all sitting in the same room, separated by individual partitions. He can view all of them throughout the 2-hour process. They have an iPad in front of them where they fill out a HAM-D and MADRS before the treatment. Then they sit in their comfy chairs doing whatever they like for the next two hours (i.e. listen to music, relax with eye masks, etc).
We are still billing 99214/99215 (depending on the severity of symptoms + 99417 x 1 for our Spravato visits. The post-administering monitoring is done by a medical assistant - not the physician - in our clinic and we haven't had any difficulty getting these codes reimbursed thus far. We also document explicitly in our treatment notes that supervision is being done by the medical assistant and that the treating physician was immediately available in the clinic, if needed (which is true).

While it may be a bit sketchy, I don't see any problem with billing monitoring codes for multiple patients at the same time. It's entirely feasible to observe multiple patients at once, as others have mentioned, depending in the physical layout of your space.

So I stand corrected, apparently something like this has been brought up before and it seems like it IS the right way to bill this. It isn't the exact same thing but falls along the same lines.


Sounds like that might actually be the way to make the whole Spravato thing work from a private perspective. Just have "Spravato Saturday" where you have 6 patients at time x2-3 times all day....basically ends up being 18 patient encounters for the day for pretty minimal actual effort.
 
So I stand corrected, apparently something like this has been brought up before and it seems like it IS the right way to bill this. It isn't the exact same thing but falls along the same lines.


Sounds like that might actually be the way to make the whole Spravato thing work from a private perspective. Just have "Spravato Saturday" where you have 6 patients at time x2-3 times all day....basically ends up being 18 patient encounters for the day for pretty minimal actual effort.

The math still doesn’t make sense. It isn’t terrible, but it’s worse than typical billing. Spravato approval takes a lot of staff logistics with insurance. If all 6 show up at once, 6 99214’s in 2 hours is lower than I would typically bill in an insurance practice. A very large room is needed for 6 recliners spaced out plus 1 psychiatrist plus a MA running around administering doses. It might work in my waiting room, but I’d need to change the waiting room furniture out and keep the next batch of patients outside. Having a large space like this is otherwise not cost effective.

Maybe with 6 extended time codes used multiple times simultaneously, the math is getting better, but I wonder how an audit would play out. United would see me essentially billing extended time x4 on 6 patients so 24 extended time codes in the same 2 hours.

Compare that to 4 99214 + 90833 with 2 regular 99214 over 6 hours. That is a fairly typical insurance 2 hours with less logistics and probably better reimbursement.
 
The math still doesn’t make sense. It isn’t terrible, but it’s worse than typical billing. Spravato approval takes a lot of staff logistics with insurance. If all 6 show up at once, 6 99214’s in 2 hours is lower than I would typically bill in an insurance practice. A very large room is needed for 6 recliners spaced out plus 1 psychiatrist plus a MA running around administering doses. It might work in my waiting room, but I’d need to change the waiting room furniture out and keep the next batch of patients outside. Having a large space like this is otherwise not cost effective.

Maybe with 6 extended time codes used multiple times simultaneously, the math is getting better, but I wonder how an audit would play out. United would see me essentially billing extended time x4 on 6 patients so 24 extended time codes in the same 2 hours.

Compare that to 4 99214 + 90833 with 2 regular 99214 over 6 hours. That is a fairly typical insurance 2 hours with less logistics and probably better reimbursement.

I agree that it's still challenging to do from a private practice perspective. I think like all of the "interventional" treatments, the key is volume as there has to be a lot of infrastructure in place whether you're treating 1 patient or 20. I think it could be doable, but you'd really have to make a point of making yourself known for doing these treatments.

There's a reason that very, very few private practice docs in the Dallas area do esketamine treatments. I'm sure there are several that do them very occasionally, but I only know of 1 that actually makes it a big part of his practice.
 
The math still doesn’t make sense. It isn’t terrible, but it’s worse than typical billing. Spravato approval takes a lot of staff logistics with insurance. If all 6 show up at once, 6 99214’s in 2 hours is lower than I would typically bill in an insurance practice. A very large room is needed for 6 recliners spaced out plus 1 psychiatrist plus a MA running around administering doses. It might work in my waiting room, but I’d need to change the waiting room furniture out and keep the next batch of patients outside. Having a large space like this is otherwise not cost effective.

Maybe with 6 extended time codes used multiple times simultaneously, the math is getting better, but I wonder how an audit would play out. United would see me essentially billing extended time x4 on 6 patients so 24 extended time codes in the same 2 hours.

Compare that to 4 99214 + 90833 with 2 regular 99214 over 6 hours. That is a fairly typical insurance 2 hours with less logistics and probably better reimbursement.

What part of the math does not make sense? 99215 + 99417 (x4) per patient, per treatment. Comes out to 5.28 wRVU each treatment. If you do 4 patients at once, that's 21.12 wRVU/2 hours. I know places that do 6 at once, or 31.68 wRVU/2 hours.

Also, the MAs do not administer doses. The patients inoculate themselves with Spravato. The MAs simply take vital signs at 40 min and then again at the 2 hour mark.
 
The math still doesn’t make sense. It isn’t terrible, but it’s worse than typical billing. Spravato approval takes a lot of staff logistics with insurance. If all 6 show up at once, 6 99214’s in 2 hours is lower than I would typically bill in an insurance practice. A very large room is needed for 6 recliners spaced out plus 1 psychiatrist plus a MA running around administering doses. It might work in my waiting room, but I’d need to change the waiting room furniture out and keep the next batch of patients outside. Having a large space like this is otherwise not cost effective.

Maybe with 6 extended time codes used multiple times simultaneously, the math is getting better, but I wonder how an audit would play out. United would see me essentially billing extended time x4 on 6 patients so 24 extended time codes in the same 2 hours.

Compare that to 4 99214 + 90833 with 2 regular 99214 over 6 hours. That is a fairly typical insurance 2 hours with less logistics and probably better reimbursement.

Well from the insurance side, CMS is basically saying, yes that is the correct way to bill it, you can bill those E+M codes simultaneously in a "group visit". They'd also end up all being 99215 + extended time codes x4-6 patients over 2 hours, for basically copy/pasting the same note for each patient. I mean that seems like a pretty laid back saturday to me to make several thousand dollars (6x 99215s would come out to around 1K based on my panels plus the 99417s additional).
 
What part of the math does not make sense? 99215 + 99417 (x4) per patient, per treatment. Comes out to 5.28 wRVU each treatment. If you do 4 patients at once, that's 21.12 wRVU/2 hours. I know places that do 6 at once, or 31.68 wRVU/2 hours.

Also, the MAs do not administer doses. The patients inoculate themselves with Spravato. The MAs simply take vital signs at 40 min and then again at the 2 hour mark.

If your pay is tied to RVU’s, go for it. Otherwise, you aren’t understanding the logistical issues here. First you need a spare room large enough for 6 patients + MA’s + yourself. That doesn’t naturally exist in the private world or someone did a bad job choosing space - increased rents. MA’s will be doing pre-administration vitals, checking ID, bringing and monitoring each administration (while they don’t personally administer it, it would be faster if they did), documenting, and then monitoring/documenting vitals at 40,120 minutes. Side effects may need to be addressed during the session. Also document and monitor transfer to driver’s vehicle. Getting approvals can take hours of staff paid time before this day happens. Add in overtime or added staff to work a Saturday.

If you are just employed and want RVU’s, go ahead and push for this. A psychiatrist in the private world planning and implementing this is very different. The local academic center is requiring a grant to run the clinic due to losing money every time.
 
If your pay is tied to RVU’s, go for it. Otherwise, you aren’t understanding the logistical issues here. First you need a spare room large enough for 6 patients + MA’s + yourself. That doesn’t naturally exist in the private world or someone did a bad job choosing space - increased rents. MA’s will be doing pre-administration vitals, checking ID, bringing and monitoring each administration (while they don’t personally administer it, it would be faster if they did), documenting, and then monitoring/documenting vitals at 40,120 minutes. Side effects may need to be addressed during the session. Also document and monitor transfer to driver’s vehicle. Getting approvals can take hours of staff paid time before this day happens. Add in overtime or added staff to work a Saturday.

If you are just employed and want RVU’s, go ahead and push for this. A psychiatrist in the private world planning and implementing this is very different. The local academic center is requiring a grant to run the clinic due to losing money every time.

Just to confirm this, we have a pretty decent Spravato volume (about 6 patients/half-day, which is all the space we have for) and it's a huge financial drain on the clinic. The only reason we offer it is because we're an academic center and our department thinks it's important for us to offer all treatments that are available, finances be damned (to a certain extent).
 
Well from the insurance side, CMS is basically saying, yes that is the correct way to bill it, you can bill those E+M codes simultaneously in a "group visit". They'd also end up all being 99215 + extended time codes x4-6 patients over 2 hours, for basically copy/pasting the same note for each patient. I mean that seems like a pretty laid back saturday to me to make several thousand dollars (6x 99215s would come out to around 1K based on my panels plus the 99417s additional).

Let’s do the math:
2 hours is otherwise doing 4 patients at 99214 + 90833 and 2 patients at 99214 only which is a fairly typical insurance practice structure. That is not high volume, adding screener codes or interactive complexity or even utilizing other rooms by other psychiatrists/counselors during normal hours. Looking at the same contract - 6 patients at 99215 + (4) 99417 would result in about $200 extra in total pre-overhead

I would open on Saturday, have multiple staff (overtime) clear the waiting room and bring in recliners (expense), put up partitions (expense) of some kind, vomit bags (expense), clean up, monitor 6 patients with side effects, extra staff prep in advance, etc. How much of that bonus $200 pre-overhead in 2 hours is left? I haven’t bothered with that exact math, but it won’t get me to clinic on Saturday.

No space is otherwise available to do this on any weekday. All Spravato patients would need to be on a weekend and then when? Another after-hours clinic?
 
Let’s do the math:
2 hours is otherwise doing 4 patients at 99214 + 90833 and 2 patients at 99214 only which is a fairly typical insurance practice structure. That is not high volume, adding screener codes or interactive complexity or even utilizing other rooms by other psychiatrists/counselors during normal hours. Looking at the same contract - 6 patients at 99215 + (4) 99417 would result in about $200 extra pre-overhead

I would open on Saturday, have staff (overtime) clear the waiting room and bring in recliners (expense), put up partitions (expense) of some kind, etc. How much of that bonus $200 in 2 hours is left?

How are you seeing 6 patients in 2 hours while billing 4 of them as 99214+90833? Gotta say, that’s stretching it a bit.
 
How are you seeing 6 patients in 2 hours while billing 4 of them as 99214+90833? Gotta say, that’s stretching it a bit.

This is under-coding for many clinics that I’ve seen numbers on. 99214 (2 diagnoses) - 9 minutes + 90833 16 min therapy = 25 minutes. 50 minutes for 2. 10 minutes for another 99214.

I recently did a review of a clinic that does 4-6 99214’s/hour for years and passed audits. This with a physician assistant that does another four/hour. Even ignoring the PA, there would be $0 additional from doing Spravato.

Another clinic I saw is doing sometimes 3 99214 + 90833/hour and passing audits, but I think that is pushing it.

If we are going to compare a leisurely insurance practice at two 99214 + 90833/hour, that person has 0 interest in Saturdays and doesn’t have the staff for this.
 
This is under-coding for many clinics that I’ve seen numbers on. 99214 (2 diagnoses) - 9 minutes + 90833 16 min therapy = 25 minutes. 50 minutes for 2. 10 minutes for another 99214.

I recently did a review of a clinic that does 4-6 99214’s/hour for years and passed audits. This with a physician assistant that does another four/hour. Even ignoring the PA, there would be $0 additional from doing Spravato.

Another clinic I saw is doing sometimes 3 99214 + 90833/hour and passing audits, but I think that is pushing it.

If we are going to compare a leisurely insurance practice at two 99214 + 90833/hour, that person has 0 interest in Saturdays and doesn’t have the staff for this.

yeah but are you actually scheduling people to come in like that? So like someone’s appointment is at 9:00, next appointment is 9:25, next appointment is at 9:50 (for the patient you anticipate to just be a 10 min followup)? And then the 10 minute patient actually has 20 minutes worth of stuff they want to tell you about….Otherwise you’re just constantly running late or waiting for the next person to show up if you knock one out in 10 minutes.

It’s just assuming you’re being 100 percent efficient there.

4x 99214s an hour actually makes more sense to me since you could do 15 min “med checks”but again this is assuming 100 percent show rate with 100 percent efficiency and everyone shows up exactly on time, you get them out exactly on time.
 
yeah but are you actually scheduling people to come in like that? So like someone’s appointment is at 9:00, next appointment is 9:25, next appointment is at 9:50 (for the patient you anticipate to just be a 10 min followup)? And then the 10 minute patient actually has 20 minutes worth of stuff they want to tell you about….Otherwise you’re just constantly running late or waiting for the next person to show up if you knock one out in 10 minutes.

It’s just assuming you’re being 100 percent efficient there.

4x 99214s an hour actually makes more sense to me since you could do 15 min “med checks”but again this is assuming 100 percent show rate with 100 percent efficiency and everyone shows up exactly on time, you get them out exactly on time.

We should probably start a new thread for this if you want to get into details, but most insurance clinics aren’t running on time regardless of specialty. I saw a specialist and wasn’t seen within 1 hour of my appointment.

Private insurance clinics routinely schedule an additional 1-2 patients/hour. Some hours if you get far behind become 6 99214’s. If close to on-time, you do therapy with 2 patients per hour and enjoy it. You could hire a counselor that does a full hour with patients that expect counseling but you are behind. This is an insurance practice, so patients will expect to be more flexible.

Out of network practices can be quite different. I have patients that refuse to transfer back to their PCP, because they would rather get refills from me in 3 minute appointments because I run on time instead of waiting to be seen. That is technically a 99214 now with 2 diagnoses.

Racemic ketamine compounded is cheap. If you are only seeing 2 patients per hour, the staff hours to get approval, order, store, Spravato would be more expensive than if you paid for compounded ketamine out of your own pocket.
 
If your pay is tied to RVU’s, go for it. Otherwise, you aren’t understanding the logistical issues here. First you need a spare room large enough for 6 patients + MA’s + yourself. That doesn’t naturally exist in the private world or someone did a bad job choosing space - increased rents. MA’s will be doing pre-administration vitals, checking ID, bringing and monitoring each administration (while they don’t personally administer it, it would be faster if they did), documenting, and then monitoring/documenting vitals at 40,120 minutes. Side effects may need to be addressed during the session. Also document and monitor transfer to driver’s vehicle. Getting approvals can take hours of staff paid time before this day happens. Add in overtime or added staff to work a Saturday.

If you are just employed and want RVU’s, go ahead and push for this. A psychiatrist in the private world planning and implementing this is very different. The local academic center is requiring a grant to run the clinic due to losing money every time.

The places I've seen are wRVU based. One is an academic clinic in the Midwest run by an attending during their admin time. Another is a stand alone psych hospital with an attached provider-based outpatient clinic. The attendings are usually inpatient doctors who see Spravato outpatients for extra wRVUs, the math I have outline above. It has been incredibly profitable for the attendings and their clinic admin do not seem to mind at all. In fact, they are using the extra Spravato wRVUs as a recruiting tactic.

Their typical day is inpatient rounding starting around 7am, then overseeing 4-6 Spravato patients/day while they do their notes 10:30-12:30. Then home. At one hospital, admin wanted to add an additional session in the afternoon but the folks I know would rather be home early, hence the inpatient career path. My hospital is building a replica model of this at our new inpatient hospital (which also has outpatient & PHP). Every attending in our group wants a piece of the pie.
 
The places I've seen are wRVU based. One is an academic clinic in the Midwest run by an attending during their admin time. Another is a stand alone psych hospital with an attached provider-based outpatient clinic. The attendings are usually inpatient doctors who see Spravato outpatients for extra wRVUs, the math I have outline above. It has been incredibly profitable for the attendings and their clinic admin do not seem to mind at all. In fact, they are using the extra Spravato wRVUs as a recruiting tactic.

Their typical day is inpatient rounding starting around 7am, then overseeing 4-6 Spravato patients/day while they do their notes 10:30-12:30. Then home. At one hospital, admin wanted to add an additional session in the afternoon but the folks I know would rather be home early, hence the inpatient career path. My hospital is building a replica model of this at our new inpatient hospital (which also has outpatient & PHP). Every attending in our group wants a piece of the pie.

The original poster was asking about Spravato in an outpatient setting. I agree that inpatient centers make more sense, especially in a setting of ECT. You could use mostly identical staff. Perform ECT with anesthesia and monitor Spravato patients across the room.

RVU’s are just complicated numbers designed to keep physician income lower. They don’t relate to actual money coming in which is vital to understand as an outpatient clinic owner considering Spravato. For instance, my outpatient academic peers were billing 90792 last I checked for evals because it had more RVU’s than a 99204 despite 99204 actually bringing in higher $.
 
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