Title: Proposed Billing Guidelines for Opioid Treatment Programs
1 Proposed Billing Guidelines for Opioid
Treatment Programs
2Proposed Billing Guidelines for Opioid Treatment
Programs
Recently, CMS has proposed Medicare Physician Fee
Schedule Proposed Rule for the year 2023. This
proposed rule also includes billing for Opioid
Treatment Programs (OTPs). These proposed billing
guidelines for Opioid Treatment Programs include
revising pricing for the drug component of the
methadone modifying the payment rate for the
non-drug component of the bundled payments for
episodes of care to base the rate for individual
therapy on a crosswalk code describing a
45-minute session allowing the OTP intake add-on
code to be furnished via two-way audio-video
communications technology and discussing SAMHSA
and DEA guidance. Opioid Treatment Programs
(OTPs) In order to stabilize the price for
methadone for CY 2023 and subsequent years, CMS
proposed to revise their methodology for pricing
the drug component of the methadone weekly bundle
and the add-on code for take-home supplies of
methadone. Under this proposal, CMS would base
the payment amount for the drug component of
HCPCS codes G2067 and G2078 for CY 2023 and
subsequent years on the payment amount for
methadone in CY 2021 and update this amount
annually to account for inflation using the PPI
for Pharmaceuticals for Human Use (Prescription).
Additionally, based on the severity of needs of
the patient population diagnosed with opioid use
disorder (OUD) and receiving services in the OTP
setting, CMS proposed to modify the payment rate
for the non-drug component of the bundled
payments for episodes of care to base the rate
for individual therapy on a crosswalk code
describing a 45-minute session, rather than the
current crosswalk to a code describing a
30-minute session. This would increase overall
payments for medication-assisted treatment and
other treatments for OUD, recognizing the longer
therapy sessions that are usually required.
3Proposed Billing Guidelines for Opioid Treatment
Programs
CMS also proposed to allow the OTP intake add-on
code to be furnished via two-way audio-video
communications technology when billed for the
initiation of treatment with buprenorphine, to
the extent that the use of audio-video
telecommunications technology to initiate
treatment with buprenorphine is authorized by the
Drug Enforcement Administration (DEA) and
Substance Abuse and Mental Health Services
Administration (SAMHSA) at the time the service
is furnished. CMS also proposes to permit the use
of audio-only communication technology to
initiate treatment with buprenorphine in cases
where audio-video technology is not available to
the beneficiary and all other applicable
requirements are met. Additionally, CMS is
clarifying that OTPs can bill Medicare for
medically reasonable and necessary services
furnished via mobile units in accordance with
SAMHSA and DEA guidance. CMS is proposing that
locality adjustments for services furnished via
mobile units would be applied as if the service
were furnished at the physical location of the
OTP registered with DEA and certified by
SAMHSA. Basics about Methadone Methadone is a
medication used to treat Opioid Use Disorder
(OUD). Methadone is a long-acting full opioid
agonist, and a schedule II controlled medication.
Methadone is a medication approved by the Food
and Drug Administration (FDA) to treat Opioid Use
Disorder (OUD) as medication-assisted treatment
(MAT), as well as for pain management. When taken
as prescribed, methadone is safe and effective.
Methadone helps individuals achieve and sustain
recovery and to reclaim active and meaningful
lives.
4Proposed Billing Guidelines for Opioid Treatment
Programs
Methadone is one component of a comprehensive
treatment plan, which includes counseling and
other behavioral health therapies to provide
patients with a whole-person approach. Methadone,
a long-acting opioid agonist, reduces opioid
craving and withdrawal and blunts or blocks the
effects of opioids. Taken daily, it is available
in liquid, powder, and diskettes forms. Patients
taking methadone to treat OUD must receive the
medication under the supervision of a
practitioner. After a period of stability (based
on progress and proven, consistent compliance
with the medication dosage), patients may be
allowed to take methadone at home between program
visits. The length of time a person receives
methadone treatment varies. According to the
National Institute on Drug Abuse publication
Principles of Drug Addiction Treatment A
Research-Based Guide (Third Edition), the length
of methadone treatment should be a minimum of 12
months. Some patients may require long-term
maintenance. Patients must work with their MAT
practitioner to gradually reduce their methadone
dosage to prevent withdrawal. Legion Health Care
Solutions is a leading medical billing company
that can assist you in revenue cycle functions
for your practice. We hope that these proposed
billing guidelines for Opioid Treatment Programs
(OTPs) would help you receive accurate insurance
reimbursement for government and private payers.
To know more about our pain management or
anesthesiology billing, you can call us at
727-475-1834 or email us at info_at_legionhealthcares
olutions.com
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