Billing for 2-Hour Spravato Monitoring
For a 2-hour Spravato monitoring session, bill one (1) unit of 99215 and zero (0) units of 99417.
Rationale Based on FDA Label Requirements
The FDA-approved Spravato label mandates that patients must be observed for at least 2 hours at each treatment session until they are clinically stable and safe to leave 1. This 2-hour monitoring period is the standard, required post-administration observation time.
CPT Code Selection
99215 (Established Patient Office Visit)
- 99215 is appropriate because it represents an established patient office visit requiring 40 minutes of total time when time-based coding is used 2
- The 2-hour Spravato monitoring session clearly exceeds the 40-minute threshold for 99215
- This code captures the base evaluation and management service during the monitoring period
99417 (Prolonged Service Add-On)
- 99417 should NOT be billed for standard 2-hour Spravato monitoring
- The provided evidence discusses 99354/99355 codes for prolonged services (first 30-74 minutes, then each additional 30 minutes) 2, but these are older CPT codes
- Critical distinction: The 2-hour monitoring is the standard required observation period per FDA labeling, not "prolonged" care beyond typical service
Important Caveats
If monitoring extends beyond 2 hours (e.g., due to persistent sedation, elevated blood pressure, or clinical instability), the FDA label states "if not [clinically stable], continue to monitor" 1. In such cases:
- Additional time beyond the standard 2-hour period may justify prolonged service codes
- Document the clinical reason requiring extended monitoring
- Verify current CPT guidelines for prolonged service coding (99417 vs 99354/99355)
Documentation requirements:
- Blood pressure assessment at approximately 40 minutes post-dose
- Monitoring for sedation, dissociation, and clinical stability
- Confirmation patient is safe to leave after 2 hours
- Any adverse events requiring extended observation
REMS program compliance is mandatory for Spravato administration, which includes the 2-hour supervised monitoring period 1, 3.