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Can you show me the source for that? I haven't been able to find it. I see a lot of best practice quoted but not the actual DEA verbiage.
Opioid rx obligations
Started by Goodlife1119
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Based on this, the 90 day visit is an extrapolated requirement??
Like agast, I was unable to find the visit requirements written anywhere. A couple years ago, my system proposed prescribers had to see patients at least q6 months. I was blown away, indicated that was not appropriate, but struggled to find any information to back up the practice of seeing people every 90 days or less…
"An individual practitioner may issue multiple prescriptions authorizing the patient to receive a total of up to a 90-day supply of a Schedule II controlled substance provided the following conditions are met..."
www.law.cornell.edu
21 CFR § 1306.12 - Refilling prescriptions; issuance of multiple prescriptions.
"An individual practitioner may issue multiple prescriptions authorizing the patient to receive a total of up to a 90-day supply of a Schedule II controlled substance provided the following conditions are met..."
21 CFR § 1306.12 - Refilling prescriptions; issuance of multiple prescriptions.
I see a lot of folks criticizing the concept of doing 90 day/12 week opioid Rx f/u's, but that is for chronic/stable/compliant pts in our practice. Other pts may be seen at 2,4,6,8 weeks depending on the situation. We have a lot of structure and monitoring in place and this approach seems to be working well. We stay away from high dose opioid regimens, in general
All good except for anyone high risk enough to require 2 week visits is too high risk to continue on opiates under my care. I have folks nearby that do both pain and addiction so they can still get the care they need.
It all depends on the patient. Everyone does not need to be seen weekly and by the same logic everyone does not need to be seen every month either. Likewise everyone should not be seen 90 days either. That is what risk stratification is for.
I have listened to those saying every 30 days is medically necessary all of the time. The evidence provided here has to make one wonder if the DEA is saying that you can write three scripts covering 90 days, why would EVERY 30 days on EVERY patient be medically necessary 100 percent of the time?
I think that the answer is evident and it is also evident that this would not even be a thing if there was no financial incentive. With that said, I cant tell you or your patient what is right to do but we need to call a spade ....a spade.
As I previously mentioned, I know of several practices that insist on this 30 day approach and then have a 6-8 week wait to get patients in. That to me is even a financial disincentive. You are prioritizing non-procedure patients over probable procedure patients. I don't mention it because it would just be helping my competitors but it makes no sense.
Do they really? Follow-ups sometimes take longer than a LESI. If this is true why would anyone do interventions.
They do in a job where you're paid purely on RVUs.
99214 = 1.92 rvu
62323 = 1.76 rvu
And the reason why even those with HOPD jobs do procedures is that you have to do some so the hospital can get their sweet facility fees. If you don't, there's no justification to pay you $60-70/rvu and you'll find yourself out of a job.
Honestly with my hospitals constant staffing issues and turnover I make significantly more with visits.
Plus G2211 adds another 0.33 to make the clinic visit 2.25 RVU
state laws may also affect prescriptions.
i dont know any state that allows refills of Schedule 2 drugs (i believe all states allow refills of Schedule 3). definitely not mine or the surrounding states.
they all allow up to 90 day scripts with "Code D __ day prescription" on the script itself.
outside of new opioid treatment, i think ive made adjustment upwards on a COT patient once in the past 3 years...
i dont know any state that allows refills of Schedule 2 drugs (i believe all states allow refills of Schedule 3). definitely not mine or the surrounding states.
they all allow up to 90 day scripts with "Code D __ day prescription" on the script itself.
i do 2, 4 or 6 week follow up right after initiation of treatment or any change in dosage usually only once.
outside of new opioid treatment, i think ive made adjustment upwards on a COT patient once in the past 3 years...
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Not really 64483 is 1.85wrvu bilateral is not double
These numbers appear to be rvu and not wrvu. fastrvu I believe is wrong.
AAPC 2026 has 1.85 wrvu for 64483
RVU Calculator - AAPC Relative Value Units
CPT® RVU calculator provides a quick analysis of the work relative value units associated with a certain volume of CPT or HCPCS codes.
www.aapc.com
These numbers appear to be rvu and not wrvu. fastrvu I believe is wrong.
AAPC 2026 has 1.85 wrvu for 64483
RVU Calculator - AAPC Relative Value Units
CPT® RVU calculator provides a quick analysis of the work relative value units associated with a certain volume of CPT or HCPCS codes.
I am seeing 64483 as a wrvu of 3.0 and practice expense/malpractice of 4.3 for total RVU of 7.3.
Maybe my source is wrong.
My source also has 62323 at 2.4 wrvus and 99214 at 1.92 wrvusThese numbers appear to be rvu and not wrvu. fastrvu I believe is wrong.
AAPC 2026 has 1.85 wrvu for 64483
RVU Calculator - AAPC Relative Value Units
CPT® RVU calculator provides a quick analysis of the work relative value units associated with a certain volume of CPT or HCPCS codes.
Update:
I appreciate the insights that others have brought to the discussion. For me building a friction less practice (within reason) is important to me. One of those things was not being responsible for existing COT therapy patients. The benefits of hospital employed practice is that even if COT therapy is not offered or these existing patients went elsewhere, there should still be enough referrals to bridge the gap.
I did consistently let admin know that I was not planning on taking over these patients. To their credit, they have worked with the current staff to transition these patients to the local private practice group which has been more than happy to accommodate these patients. I think time will tell how much this will affect me financially. However, for the piece of mind and the lower risk, this is worth it for me. I think in the future I may start some future patients on COT therapy, but it would get to be under my own terms.
I appreciate the insights that others have brought to the discussion. For me building a friction less practice (within reason) is important to me. One of those things was not being responsible for existing COT therapy patients. The benefits of hospital employed practice is that even if COT therapy is not offered or these existing patients went elsewhere, there should still be enough referrals to bridge the gap.
I did consistently let admin know that I was not planning on taking over these patients. To their credit, they have worked with the current staff to transition these patients to the local private practice group which has been more than happy to accommodate these patients. I think time will tell how much this will affect me financially. However, for the piece of mind and the lower risk, this is worth it for me. I think in the future I may start some future patients on COT therapy, but it would get to be under my own terms.
Need others to chime in with sources. ASIPP?
62323 is 1.76 RVU now in 2026 with the 2.5% “efficiency decrease” from CMS.
I don't know where you're getting your numbers from in this or your other post but they seem significantly inflated.
Just go to the CMS physician fee lookup site.
62323 is 1.76
64493: 1.48
64494: 0.98
99214: 1.92
So a med refill taking 5 min gives 1.92.
A LESI gives 1.76
A BL 2 lvl MBB is certainly the biggest bang for your buck in terms of time at 4.35 but you're more likely to rack up a ton of 99214s than you are a ton of 64493,50+64494,50.
Although there are instances where someone had a 2-week follow-up due to a compliance issue that would be more common to be someone new to opioids or switching products so it is really more to be a close follow-up on progress rather than a compliance or safety concern
I am a rural enough that I do not really have a lot of good referral options -- if I feel they are too high risk for me that I probably just will not put them on them in the first place. There is a big multi office pain group in our state they did a lot of APP driven high risk opioid management that went suddenly out of business which definitely created some ripple effects although I was geographically removed enough to not be affected too much
What I have been doing lately if someone has pain that would typically qualify for opioids but they are having compliance issues they can either be discontinued/weaned or they can go on a Butrans patch and that has actually worked pretty well. So far they seem to stay pretty compliant with the Butrans when they could not with oral opioids
Ok my mistake....I have to look and will look at my contract with the HOPD.
direct from system, last year
62323 gives 1.8 wRVU
99214 gave 1.5 wRVU (older conversion - newer is 1.9)
your numbers are RVU, not wRVU, which is the combination of wRVU, facility RVU and malpractice component, which is why it is 7.3 RVU as you mentioned above for MBB
62323 gives 1.8 wRVU
99214 gave 1.5 wRVU (older conversion - newer is 1.9)
your numbers are RVU, not wRVU, which is the combination of wRVU, facility RVU and malpractice component, which is why it is 7.3 RVU as you mentioned above for MBB
Frictionless life would be easily meeting your rvu quota. You will have much more stress when it is year 3 and you are way behind quota still than refilling some elderly people’s tramadol and Norco. Don’t be afraid of patients on opioids. I have a lot of paras, quads, adult cp, terrible RA, etc in addition to the more typical failed backs.
