100-04 Medicare Claims Processing Manual: Chapter 39 – Opioid Treatment Programs (OTPs)

us-cms-medicare-manuals-pub-100-04-chapter-39-opioid-treatment-programs-otps100-04 Medicare Claims Processing Manual: Chapter 39 – Opioid Treatment Programs (OTPs)Guidance

Medicare Claims Processing Manual
Chapter 39 – Opioid Treatment Programs (OTPs)
Table of Contents
(Rev. 13572; Issued: 03-03-26)
Transmittals for Chapter 39
10 - General
20 - Statutory authority for OTPs billing Medicare
30 - Bundled payments for Opioid Use Disorder (OUD) treatment services
30.1 - Duration of bundle
30.2 - Requirements for an Episode
30.3 - Non-drug episode of care
30.4 - New drugs
30.5 - Site of service (telecommunications)
30.6 - Coding
30.6.1 - Adjustments to Bundled Payment Rate
30.7 - Cost Sharing
30.8 - Locality Adjustments
30.9 - Annual Updates
40 - Practitioner Claims submission– A/B MAC (B)
40.1 - Place of Service
40.2 - Date of Service
40.3 - Prescribing Individuals
50 – Institutional Opioid Treatment Program (OTP) Services – A/B MAC (A)
50.1 Special Opioid Treatment Program Billing Requirements for Hospitals, Critical Access
Hospitals, and Free-Standing Opioid Treatment Program Facilities
60 – OUD Diagnosis Code
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10 - General
(Rev. 4524: Issued; 02-14-20: Effective; 01-01-20: Implementation: 03-16-20)
This chapter provides claims processing instructions for Opioid Treatment Programs (OTPs).
The Medicare Benefit Policy Manual, Chapter 17, provides coverage policy for OTPs.
20 - Statutory authority for OTPs billing Medicare
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
Section 2005 of the SUPPORT Act amended section 1861 of the Act by adding a new subsection (jjj)(2) to
define an OTP as an entity meeting the definition of OTP in 42 CFR 8.2 or any successor regulation (that is,
a program or practitioner engaged in opioid treatment of individuals with an opioid agonist treatment
medication registered under 21 U.S.C. 823(g)(1)), that meets the additional requirements set forth in
subparagraphs (A) through (D) of section 1861(jjj)(2) of the Act. Specifically that the OTP: is enrolled
under section 1866(j) of the Act; has in effect a certification by the Substance Abuse and Mental Health
Services Administration (SAMHSA) for such a program; is accredited by an accrediting body approved by
SAMHSA; and meets such additional conditions as the Secretary may find necessary to ensure the health
and safety of individuals being furnished services under such program and the effective and efficient
furnishing of such services.
We defined “opioid treatment program” at § 410.67(b) as an entity that is an OTP as defined in § 8.2 (or any
successor regulation) that meets the applicable requirements for an OTP. For an OTP to participate and
receive payment under the Medicare program, the OTP must be enrolled under section 1866(j) of the Act,
have in effect a certification by SAMHSA for such a program, and be accredited by an accrediting body
approved by SAMHSA. Additionally, payments made to OTPs under the Medicare OTP benefit must be for
the treatment of an opioid use disorder (OUD).
30 - Bundled payments for Opioid Use Disorder (OUD) treatment services
(Rev. 4524: Issued; 02-14-20: Effective; 01-01-20: Implementation: 03-16-20)
The bundled payment rates are calculated by combining the drug component and the non-drug components.
30.1 - Duration of bundle
(Rev. 4524: Issued; 02-14-20: Effective; 01-01-20: Implementation: 03-16-20)
An episode of care is defined at § 410.67(b) as a 1-week (contiguous 7-day) period.
There is no maximum number of weeks for a course of treatment for OUD.
30.2 - Requirements for an Episode
(Rev. 12418; Issued: 12-21-23; Effective: 01-01-24; Implementation: 01-24-24)
In recognition that there is a range of service intensity depending on the severity of a patient’s OUD
and stage of treatment, a “full weekly bundle” may consist of a very different frequency of services for
a patient in the initial phase of treatment compared to a patient in the maintenance phase of treatment,
or based on other factors such as pregnancy or relapse.
The threshold to bill the weekly episode is the delivery of at least one service in the weekly bundle
(from either the drug or non-drug component) to the patient during the week that corresponds to
the episode of care. If no drug was provided to the patient during that episode, the OTP must bill
the G-code describing the weekly bundle not including the drug (HCPCS code G2074) and the
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threshold to bill would be at least one service in the non-drug component. If a drug was provided
with or without additional non-drug component services, the appropriate G-code describing the
weekly bundle that includes the drug furnished may be billed.
For OTP intensive outpatient services, the threshold to bill HCPCS code G0137 for these services is
a minimum of nine services furnished over a 7-continguous day period. These services are described
in § 410.67(b)(ix) in the definition of “OTP intensive outpatient services.” A minimum of nine
OTP intensive outpatient services, regardless of the length or time duration of these services, meets
the threshold to bill, including if services of the same type are furnished more than once a week as
long as all services are medically reasonable and necessary for the treatment of OUD. However, an
OTP may not count an intensive outpatient program service for the purposes of the nine-service
threshold if that same service is being used to qualify for billing other weekly bundles and add-on
codes under the OTP benefit. Additionally, to bill HCPCS code G0137, a physician or non-
physician practitioner (as defined in section 1842(b)(18)(C) of the Act) must certify that the
individual has a need for a minimum of nine hours of services per week and requires a higher level
of care intensity compared to other non-intensive outpatient OTP services. A physician or non-
physician practitioner, as permitted by state law and scope of practice requirements, must also meet
requirements for certification, plan of treatment, and recertification requirements as set forth in §
424.24(d)(1) through (3) for the purposes of furnishing OTP intensive outpatient services.
30.3 - Non-drug episode of care
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
HCPCS code G2074 describes a non-drug episode of care. This provides a mechanism for OTPs to bill for
non-drug services, including substance use counseling, individual and group therapy, and toxicology testing,
that are rendered during weeks when a medication is not administered, for example, in cases where a patient
is being treated with injectable buprenorphine or naltrexone on a monthly basis.
30.4 - New drugs
(Rev. 4524: Issued; 02-14-20: Effective; 01-01-20: Implementation: 03-16-20)
We anticipate that there may be new Food and Drug Administration (FDA)-approved opioid agonist and
antagonist treatment medications to treat OUD in the future.
OTPs may bill for an episode of care using the medication not otherwise specified (NOS) code (HCPCS
code G2075) in the scenario where an OTP furnishes MAT using a new FDA-approved opioid agonist or
antagonist medication for OUD treatment that is not specified in one of our existing codes. In such cases, the
typical or average maintenance dose would be used to determine the drug cost for the new bundle, which
contractors would then add to the non-drug component payment amount that corresponds with the relevant
payment for drug administration (oral, injectable, or implantable) to determine the total bundled payment for
the episode of care. Pricing for the drug component should be determined based on the relevant pricing
methodology as described in the CY 2020 Physician Fee Schedule final rule or through invoice pricing in
the event the information necessary to apply the relevant pricing methodology is not available.
30.5 - Site of service (telecommunications)
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
During the Public Health Emergency (PHE) for the COVID-19 pandemic, CMS allowed various
flexibilities for OUD treatment services furnished by OTPs via communication technology, including
allowing the therapy and counseling portions of the weekly bundles of services furnished by OTPs,
additional counseling or therapy payable under the add-on code for additional counseling or therapy, the
OTP intake add-on code for the initiation of treatment with buprenorphine, and periodic assessments to be
furnished using audio-only telephone calls rather than via two-way interactive audio-video
communication technology if beneficiaries did not have access to two-way audio/video communications
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technology, provided all other applicable requirements were met. This included instances when the
beneficiary was not capable of, or does not consent to, the use video technology for the service. All these
aforementioned flexibilities have been made permanent either during the COVID-19 PHE or following
the PHE which ended May 11, 2023.
In total, CMS allows the following flexibilities for use of communication technology for OUD
treatment services furnished by OTPs, as clinically appropriate and in compliance with all applicable
requirements:
• 	Two-way interactive audio-video communication technology
o 	Substance use counseling and individual and group therapy services included in the
bundled payment
o 	The add-on code for additional counseling and therapy
o 	Periodic assessments
o 	Initiation of treatment with buprenorphine if authorized by DEA and SAMHSA at the
time the service is furnished
o 	Initiation of treatment with methadone if authorized by DEA and SAMHSA at the time
the service is furnished
• 	Audio-only communication technology, if beneficiaries do not have access to two-way audio-
video communications technology, including instances when the beneficiary is not capable of,
or does not consent to, the use of video technology for the service:
o 	Substance use counseling and individual and group therapy services included in the
bundled payment
o 	The add-on code for additional counseling and therapy
o 	Periodic assessments
o 	Initiation of treatment with buprenorphine if authorized by DEA and SAMHSA at the
time the service is furnished
Beginning January 1, 2025, OTPs may bill the OTP intake add-on code (HCPCS code G2076) when
used for the initiation of treatment with methadone when furnished via two-way audio-video
communications technology. This is permitted if an OTP practitioner determines that an adequate
evaluation of the patient can be accomplished through audio-video communication technology, to the
extent that the use of audio-video telecommunications technology to initiate treatment with methadone
is authorized by DEA and SAMHSA at the time the service is furnished, and all other applicable
requirements are met. OTPs may bill the OTP intake add-on code (HCPCS code G2076) for the use of
audio-only initiation of treatment with methadone if pursuant to the exception specified in §
8.12(f)(2)(v)(A), which allows for the use of audio-only devices when the patient is in the presence of a
licensed practitioner who is registered to prescribe (including dispense) controlled medications, and
when audio-visual technologies are not available or their use is not feasible for a patient. The licensed
practitioner would need to be present in the same room as the patient and be available to conduct the
visual component of the examination.
OTPs providing intensive outpatient services to Medicare beneficiaries with an OUD shall not receive
payment under Medicare part B if these services are furnished via audio-video or audio-only
communications technology.
CMS expects OTPs to add Modifier 93 (Synchronous telemedicine service rendered via telephone
or other real-time interactive audio-only telecommunications system) to the claim for counseling
and therapy provided via audio-only telecommunications using HCPCS code G2080, as well as for
intake activities and periodic assessments furnished using audio-only communication technology.
Additionally, CMS expects OTPs to add Modifier 95 (Synchronous Telemedicine Service
Rendered via Real-Time Interactive Audio and Video Telecommunications System) to the claim
for counseling and therapy provided via audio-video telecommunications using HCPCS code
G2080, as well as for intake activities and periodic assessments furnished using audio and video
communication technology.
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As OTP services are not PFS services, no originating site facility fee (HCPCS code Q3014) applies to
OUD treatment services, and OTPs are not authorized to bill for the originating site facility fee.
Additionally, the payment for the substance use counseling and individual and group therapy are
included in the bundled payment rates made to OTPs; therefore, the practitioner furnishing the service
remotely should not bill separately for the service.
30.6 – Coding
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
The codes describing bundled payments made to OTPs are HCPCS codes G2067-G2069, G2073-G2075,
and G0533. There are add-on codes described by HCPCS codes G2076-G2080, HCPCS codes G2215,
G2216, G1028, G0137, G0532, and G0534-G0536. Only an entity enrolled with Medicare as an OTP can
bill these codes. Additionally, OTPs are limited to billing only these codes describing bundled payments,
and may not bill for other codes, such as those paid under the PFS.
The coding structure for OUD treatment services varies by the medication administered. There are G codes
for weekly bundles describing treatment with methadone, oral buprenorphine, and injectable buprenorphine,
monthly bundles describing treatment with extended-release injectable naltrexone and injectable
buprenorphine, a non-drug bundle, and one for a medication not otherwise specified (see full list of codes
below).
The code describing the bundled payment for an episode of care with a medication not otherwise specified
(HCPCS code G2075) should be used when the OTP furnishes MAT with a new opioid agonist or antagonist
treatment medication approved by the FDA under section 505 of the FFDCA for the treatment of OUD.
OTPs may use this code until CMS has the opportunity to propose and finalize a new G code to describe the
bundled payment for treatment using that drug and price it accordingly in the next rulemaking cycle.
HCPCS code G2075 should not be used when the drug being administered is not a new opioid agonist or
antagonist treatment medication approved by the FDA under section 505 of the FFDCA for the treatment of
OUD, and therefore, for which Medicare would not have the authority to make payment since section
1861(jjj)(1)(A) of the Act requires that the medication must be an opioid agonist or antagonist treatment
medication approved by the FDA under section 505 of the FFDCA for the treatment of OUD.
HCPCS code G2074, which describes a non-drug bundle, can be billed for services furnished during an
episode of care when a medication is not administered, but other services in the bundle are furnished. For
example, when a patient receives a buprenorphine injection on a monthly basis, the OTP will only require
payment for the medication during the first week of the month when the injection is given, and therefore,
would bill the code describing the bundle that includes injectable buprenorphine during the first week of the
month and would bill the code describing the non-drug bundle for the remaining weeks in that month for
services such as substance use counseling, individual and group therapy, and toxicology testing.
Some of the bundled payment codes describe a drug that is typically only administered once per month, such
as the injectable drugs. Consistent with FDA labelling, CMS does not generally expect the codes describing
bundled payments including the monthly injectable drugs (HCPCS codes G2069 and G2073) to be furnished
more than once every 4 weeks. In those cases, the code describing the bundled payment that includes the
cost of the drug would be billed during the week that the drug is administered, and if at least one service is
furnished in a subsequent week, the non-drug bundle would be billed. For example, in the case of a patient
receiving injectable buprenorphine, CMS would expect that HCPCS code G2069 would be billed for the
week during which the injection was administered and that HCPCS code G2074, which describes a bundle
not including the drug, would be billed during any subsequent weeks that at least one non-drug service is
furnished until the injection is administered again, at which time HCPCS code G2069 would be billed again
for that week.
CMS understands there are limited clinical scenarios when a beneficiary may be appropriately furnished
OUD treatment services at more than one OTP within a 7 contiguous day period, such as for guest dosing or
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when a beneficiary transfers care between OTPs. In these limited circumstances, each of the involved OTPs
may bill the appropriate HCPCS codes that reflect the services furnished to the beneficiary. CMS expects
that both OTPs involved would provide sufficient documentation in the patient’s medical record to reflect
the clinical situation and services provided. Additionally, in instances in which a patient is switching from
one drug to another, the OTP should only bill for one code describing a weekly bundled payment for that
week and should determine which code to bill based on which drug was furnished for the majority of the
week.
Modifier 59
CMS notes that as HCPCS codes G2067 – G2069, and G2073-G2075, cover episodes of care of 7
contiguous days, CMS will not permit an OTP to bill any of these codes for the same beneficiary more than
once per 7 contiguous day period. However, there may be certain circumstances when the OTP has a valid
reason for billing the bundled payments (G2067 – G2069 and G2073-G2075) more than once in a 7-day
period, such as when a patient is first beginning treatment and the OTP needs to synch that patient up with
the OTP’s standard weekly billing cycle, or during holiday weeks when the OTP may be closed for a portion
of the week. In these circumstances when the OTP has a valid reason for billing these bundles more than
once per 7 contiguous day period, OTPs should append modifier 59 to the claim and document the valid
reason (including providing sufficient documentation) for billing more than one bundled payment for an
episode of care.
30.6.1 - Adjustments to Bundled Payment Rate
(Rev. 13572; Issued: 03-03-26; Effective: 01-01-26; Implementation: 06-02-26)
There are add-on codes for intake activities, periodic assessments, take-home supplies of methadone, take
home supplies of oral buprenorphine, additional counseling or therapy services furnished, take-home
supplies of naloxone, intensive outpatient program services, take-home supplies of nalmefene,
coordinated care and/or referral services, patient navigational services, and peer recovery support
services.
CMS notes that the add-on code describing intake activities (HCPCS code G2076) should only be billed
for new patients (that is, patients starting treatment at the OTP).
There are two add-on codes that describe take-home doses of medication, one for take-home supplies of
methadone (HCPCS code G2078), which describes up to 7 additional days of medication, and can be
billed along with the respective weekly bundled payment in units of up to 3 (for a total of up to a one
month supply), and one for take-home supplies of oral buprenorphine (HCPCS code G2079), which also
describes up to 7 additional days of medication and can be billed along with the base bundle in units of up
to 3 (for a total of up to a 1 month supply). SAMHSA allows a maximum take-home supply of one month
of medication; therefore, CMS does not expect the add-on codes describing take-home doses of
methadone and oral buprenorphine to be billed any more than 3 times in one month (in addition to the
weekly bundled payment). The add-on code for take-home doses of methadone can only be used with the
methadone weekly episode of care code (HCPCS code G2067). Similarly, the add-on code for take-home
doses of oral buprenorphine can only be used with the oral buprenorphine weekly episode of care code
(HCPCS code G2068).
HCPCS code G2080 may be billed when counseling or therapy services are furnished that substantially
exceed the amount specified in the patient’s individualized treatment plan. OTPs are required to document
the medical necessity for these services in the patient’s medical record.
OTPs billing for intensive outpatient services (G0137) must be furnishing these services as part of a
distinct and organized intensive ambulatory treatment program for the treatment of Opioid Use Disorder,
and as part of a program that offers less than 24-hour daily care other than in an individual's home or in
an inpatient or residential setting. By billing G0137, OTPs are attesting that these intensive outpatient
services are reasonable and necessary for the diagnosis or active treatment of the individual's condition;
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are reasonably expected to improve or maintain the individual's condition and functional level and to
prevent relapse or hospitalization; and are furnished in accordance with a physician or non-physician
practitioner (as defined in section 1842(b)(18)(C) of the Act) certification and plan of care, as permitted
by State law and scope of practice requirements. A physician or non-physician practitioner must certify
that the individual has a need for a minimum of nine hours of services per week and requires a higher
level of care intensity compared to other non-intensive outpatient OTP services. FDA-approved opioid
agonist or antagonist medications for the treatment of OUD, opioid antagonist medications for the
emergency treatment of known or suspected opioid overdose, or toxicology testing, do not count as
payable OTP intensive outpatient services but if rendered, should be billed using existing bundles and/or
add-on codes as long as all other applicable requirements are met.
OTPs may furnish evidence-based assessments as part of intake activities (HCPCS code G2076) and
periodic assessments (HCPCS code G2076), as long as these assessments are medically reasonable and
necessary for the diagnosis or treatment of an OUD. OTPs should have a reason to believe unmet needs or
the need for harm reduction intervention or recovery support services identified during such an assessment
could interfere with the OTP’s ability to diagnose or treat the patient’s OUD. CMS does not require that
OTPs utilize a specific assessment tool when furnishing evidence-based assessments, but CMS expects that
these tools are validated and will allow the OTP to identify more specific individual-level needs as part of
the care plan, including considerations to potential harm reduction interventions and recovery support
service needs. CMS requires that when billing for evidence-based assessments as part of intake activities
(HCPCS code G2076) and periodic assessments (HCPCS code G2076), that OTPs continue to abide by
SAMHSA certification requirements at § 8.12(f)(4). CMS notes that since intake activities may only be
billed for new patients (that is, patients starting treatment at the OTP), additional evidence-based
assessments provided following intake at an OTP should be billed as part of periodic assessments (HCPCS
code G2076), as long as all other requirements are met.
OTPs may additionally bill G0534 for coordinated care and/or referral services, when an OTP coordinates
care or provides referral or linkage services to adequate and accessible community resources or community-
based organizations that address a patient’s identified unmet needs, or the need and interest for harm
reduction interventions and recovery support services, which may limit the ability of an OTP to diagnose or
treat a patient’s OUD. These community-based organizations may include, but are not limited to, harm
reduction organizations, peer support organizations, housing agencies, job training programs, recovery
centers, food assistance or distribution programs, residential programs, and educational services.
When a patient with an OUD requires additional navigational services to navigate multiple settings of care
and to accomplish (Medications for opioid use disorder) MOUD treatment and recovery goals, they may
qualify for patient navigational services (G0535) and/or peer recovery support services (G0536). OTPs can
bill for patient navigational services or peer recovery support services when an OTP provides these services
either directly or by referral. While OTPs may choose to refer patients with an OUD to peer recovery
support services and patient navigation services outside the OTP, HCPCS codes G0535 and G0536 are only
payable to OTPs. Patient navigational services help the patient with an OUD navigate multiple settings of
care, including by identifying care providers or recovery supportive services, communicating with other
health care or social service providers and securing appointments for patients, building patient self-advocacy
and communication skills, and facilitating patient-driven goal-setting and action plans for MOUD treatment
and recovery. OTPs can bill for peer recovery support services (G0536) that are performed by individuals
either with knowledge of an OUD, or with lived experience of an OUD, and who provide support, coaching,
mentorship, or inspiration to patients with an OUD to meet various MOUD treatment and recovery goals.
These peer recovery support services may assist Medicare beneficiaries with an OUD to stay engaged in
treatment at an OTP; connect patients with other peer support networks or recovery services in the
community; conduct interviews of the patient to understand their background, needs, and goals, and then
propose or strategize means for accomplishing such treatment and recovery goals. We expect OTPs
document in the patient’s care plan how these aforementioned services (HCPCS codes G0534-G0536) relate
to the diagnosis or treatment of an OUD prior to billing Medicare for these services.
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The codes and long descriptors for the OTP bundled services and add-on services are:
● HCPCS 	code 	G2067: 	Medication 	assisted 	treatment, 	methadone; 	weekly 	bundle 	including
dispensing and/or administration, substance use counseling, individual and group therapy, and
toxicology testing, if performed (provision of the services by a Medicare-enrolled Opioid Treatment
Program).
● HCPCS code G2068: Medication assisted treatment, buprenorphine (oral); weekly bundle including
dispensing and/or administration, substance use counseling, individual and group therapy, and
toxicology testing if performed (provision of the services by a Medicare-enrolled Opioid Treatment
Program).
● HCPCS code G2069: Medication assisted treatment, buprenorphine (injectable) administered on a
monthly basis; bundle including dispensing and/or administration, substance use counseling,
individual and group therapy, and toxicology testing if performed (provision of the services by a
Medicare-enrolled Opioid Treatment Program).
● HCPCS 	code 	G2073: 	Medication 	assisted 	treatment, 	naltrexone; 	weekly 	bundle 	including
dispensing and/or administration, substance use counseling, individual and group therapy, and
toxicology testing if performed (provision of the services by a Medicare-enrolled Opioid Treatment
Program).
● HCPCS code G2074: Medication assisted treatment, weekly bundle not including the drug,
including substance use counseling, individual and group therapy, and toxicology testing if
performed (provision of the services by a Medicare-enrolled Opioid Treatment Program).
● HCPCS code G0533: Medication assisted treatment, buprenorphine (injectable) administered on a
weekly basis; weekly bundle including dispensing and/or administration, substance use counseling,
individual and group therapy, and toxicology testing if performed (provision of the services by a
Medicare-enrolled Opioid Treatment Program).
● HCPCS code G2075: Medication assisted treatment, medication not otherwise specified; weekly
bundle including dispensing and/or administration, substance use counseling, individual and group
therapy, and toxicology testing, if performed (provision of the services by a Medicare-enrolled
Opioid Treatment Program).
● HCPCS code G0137: Intensive outpatient services; minimum of nine services over a 7- contiguous
day period, which can include individual and group therapy with physicians or psychologists (or
other mental health professionals to the extent authorized under State law); occupational therapy
requiring the skills of a qualified occupational therapist; services of social workers, trained
psychiatric nurses, and other staff trained to work with psychiatric patients; drugs and biologicals
furnished for therapeutic purposes, excluding opioid agonist and antagonist medications that are
FDA-approved for use in treatment of OUD or opioid antagonist medications for the emergency
treatment of known or suspected opioid overdose; individualized activity therapies that are not
primarily recreational or diversionary; family counseling (the primary purpose of which is treatment
of the individual’s condition); patient training and education (to the extent that training and
educational activities are closely and clearly related to individual’s care and treatment); diagnostic
services (not including toxicology testing); (provision of the services by a Medicare-enrolled Opioid
Treatment Program); List separately in addition to code for primary procedure, if applicable
● HCPCS code G2076: Intake activities, including initial medical examination that is conducted by an
appropriately licensed practitioner and preparation of a care plan, which may be informed by
administration of a standardized, evidence-based assessment , and that includes the patient’s goals and
mutually agreed-upon actions for the patient to meet those goals, including harm reduction
interventions; the patient’s needs and goals in the areas of education, vocational training, and
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employment; and the medical and psychiatric, psychosocial, economic, legal, housing, physical activity
and/or nutrition needs and other recovery support services that a patient needs and wishes to pursue,
conducted by an appropriately licensed/credentialed personnel (provision of the services by a
Medicare-enrolled Opioid Treatment Program); List separately in addition to each primary code.
● HCPCS code G2077: Periodic assessment; assessing periodically by an OTP practitioner and includes
a review of MOUD dosing, treatment response, other substance use disorder treatment needs,
responses and patient-identified goals, and other relevant physical, nutrition and psychiatric treatment
needs and goals; may be informed by administration of a standardized, evidence-based assessment, or
the need and interest for harm reduction interventions and recovery support services (provision of the
services by a Medicare-enrolled Opioid Treatment Program); List separately in addition to each
primary code.
● HCPCS code G2078: Take-home supply of methadone; up to 7 additional day supply (provision of the
services by a Medicare-enrolled Opioid Treatment Program); List separately in addition to code for
primary procedure.
● HCPCS code G2079: Take-home supply of buprenorphine (oral); up to 7 additional day supply
(provision of the services by a Medicare-enrolled Opioid Treatment Program); List separately in
addition to code for primary procedure.
● HCPCS code G2080: Each additional 30 minutes of counseling or group or individual therapy in a
week of medication assisted treatment, (provision of the services by a Medicare-enrolled Opioid
Treatment Program); List separately in addition to code for primary procedure.
● HCPCS code G2215: Take-home supply of nasal naloxone; 2-pack of 4mg per 0.1 mL nasal spray
(provision of the services by a Medicare-enrolled Opioid Treatment Program); List separately in
addition to code for primary procedure.
● HCPCS code G2216: Take-home supply of injectable naloxone (provision of the services by a
Medicare- enrolled Opioid Treatment Program); List separately in addition to code for primary
procedure.
● HCPCS code G1028: Take-home supply of nasal naloxone; 2-pack of 8mg per 0.1 mL nasal spray
(provision of the services by a Medicare-enrolled Opioid Treatment Program); List separately in
addition to code for primary procedure.
● HCPCS code G0532: Take-home supply of nasal nalmefene hydrochloride; one carton of two, 2.7 mg
per 0.1 mL nasal sprays (provision of the services by a Medicare-enrolled Opioid Treatment
Program);(List separately in addition to each primary code).
● HCPCS code G0534: Coordinated care and/or referral services, such as to adequate and accessible
community resources to address unmet health-related social needs, including harm reduction
interventions and recovery support services a patient needs and wishes to pursue, which significantly
limit the ability to diagnose or treat an opioid use disorder; each additional 30 minutes of services
(provision of the services by a Medicare-enrolled Opioid Treatment Program); List separately in
addition to each primary code).
● HCPCS code G0535: Patient navigational services, provided directly or by referral; including helping
the patient to navigate health systems and identify care providers and supportive services, to build
patient self-advocacy and communication skills with care providers, and to promote patient-driven
action plans and goals; each additional 30 minutes of services (provision of the services by a
Medicare-enrolled Opioid Treatment Program); List separately in addition to each primary code).
● HCPCS code G0536: Peer recovery support services, provided directly or by referral; including
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leveraging knowledge of the condition or lived experience to provide support, mentorship, or
inspiration to meet OUD treatment and recovery goals; conducting a person-centered interview to
understand the patient’s life story, strengths, needs, goals, preferences, and desired outcomes;
developing and proposing strategies to help meet person-centered treatment goals; assisting the patient
in locating or navigating recovery support services; each additional 30 minutes of services (provision
of the services by a Medicare-enrolled Opioid Treatment Program); List separately in addition to each
primary code).
Note: Effective January 1, 2025, HCPCS codes G2070 through G2072 will be deleted because the
buprenorphine implant (Probuphine ®) reflected within these bundled payments was discontinued on
October 19, 2020. There are currently no other generic equivalent available for buprenorphine implants
30.7 - Cost Sharing
(Rev. 10665: Issued; 03-16-21: Effective; 01-01-21: Implementation: 04-15-21)
There is zero beneficiary copayment for the codes billed by OTPs. However, the Part B deductible does
apply, as mandated for all Part B services by section 1833(b) of the Act.
30.8 - Locality Adjustments
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
The payment amounts for the non-drug component of the bundled payment for an episode of care, and the
adjustments for counseling or therapy, intake activities, periodic assessments, take-home supplies of
naloxone, take-home supplies of nalmefene, intensive outpatient program services, coordinated care and/or
referral services, patient navigational services, and peer recovery support services (HCPCS codes G2067-
G2069, G2073-G2077, G2080, G2215, G2216, G1028, G0137, and G0532- G0536) will be geographically
adjusted using the Geographic Adjustment Factor (GAF). Additionally, for purposes of the GAF, OUD
treatment services that are furnished via an OTP mobile unit will be treated as if they were furnished at the
physical location of the OTP registered with the Drug Enforcement Administration (DEA) and certified by
SAMHSA.
30.9 - Annual Updates
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
The payment amounts for the non-drug component of the bundled payment for an episode of care, and the
adjustments for counseling or therapy, intake activities, periodic assessments, take-home supplies of
naloxone, take-home supplies of nalmefene, intensive outpatient program services, coordinated care and/or
referral services, patient navigational services, and peer recovery support services (HCPCS codes G2067-
G2069, G2073-G2077, G2080, G2215, G2216, G1028, G0137, and G0532-G0536) will be updated annually
using the Medicare Economic Index.
40 - Practitioner Claims submission – A/B MAC (B)
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
Beginning January 1, 2020, claims for OTP services are submitted using the 837P transaction to
transmit health care claims electronically, or using the CMS-1500 (the paper version of the 837P).
Beginning January 1, 2021, OTPs may apply on the Medicare Enrollment Application for Institutional
Providers (CMS-855A) or through the Internet-based Provider Enrollment, Chain and Ownership
System (PECOS)(837I) when they enroll in the Medicare Program. These providers will submit
claims using the CMS-1450.
HCPCS codes G2067-G2069, G2073-G2077, G0137, and G0533 cover episodes of care of 7 continuous
days and cannot be billed for the same patient more than once per 7 continuous day period.
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HCPCS codes G2076-G2080, G0137, and G0534-G0536 are add-on codes that are billed in addition to
one of the base bundle codes described by HCPCS codes G2067-G2069, G2073-G2077, and G0533.
Consistent with FDA labeling, HCPCS codes G2069 and G2073 should not be used more than once every
4 weeks.
HCPCS codes G2078 and G2079 may be billed in multiple units, up to 3 in one month (in addition to
the base bundle code).
HCPCS codes G2215, G2216, and G0532 are limited to being billed once every 30 days, however,
exceptions to this limit are allowed in the case where the beneficiary overdoses and uses the initial
supply of naloxone or nalmefene dispensed by the OTP to the extent that it is medically reasonable and
necessary to furnish additional naloxone or nalmefene. If an additional supply of naloxone or
nalmefene is needed within 30 days of the original supply being provided, OTPs must document in the
medical record the reason for the exception. HCPCS code G2216 (injectable naloxone) is contractor-
priced for CY 2021.
Patients may be appropriately given OUD services at more than one OTP within a 7 day period in
certain limited clinical situations, such as for guest dosing or when a patient transfers care between
OTPs. Each of the involved OTPs may bill the appropriate HCPCS codes for the services provided to
the patient, but both OTPs must maintain sufficient medical record documentation to reflect the clinical
situation and services provided.
In instances in which a patient is switching from one drug to another, the OTP should only bill for one
code describing a weekly bundled payment for that week and should determine which code to bill based
on which drug was furnished for the majority of the week.
40.1 - Place of Service
(Rev. 4524: Issued; 02-14-20: Effective; 01-01-20: Implementation: 03-16-20)
Claims for OTP services should use Place of Service code 58 (Non-residential Opioid Treatment Facility – a
location that provides treatment for OUD on an ambulatory basis. Services include methadone and other
forms of MAT).
40.2 - Date of Service
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
For the codes that describe a weekly bundle (HCPCS codesG2067-G2069, G2073-G2077, and G0533) as
well as HCPCS code G0137, one week is defined as 7 contiguous days. OTPs may choose to apply a
standard billing cycle by setting a particular day of the week to begin all episodes of care. In this case, the
date of service would be the first day of the OTP’s billing cycle. If a beneficiary starts treatment at the
OTP on a day that is in the middle of the OTP’s standard weekly billing cycle, the OTP may still bill the
applicable code for that episode of care provided that the threshold to bill for the code has been met.
Alternatively, OTPs may choose to adopt weekly billing cycles that vary across patients. Under this
approach, the initial date of service will depend upon the day of the week when the patient was first
admitted to the program or when Medicare billing began. Therefore, under this approach of adopting
weekly billing cycles that vary across patients, when a patient is beginning treatment or re-starting
treatment after a break in treatment, the date of service would reflect the first day the patient was seen
and the date of service for subsequent consecutive episodes of care would be the first day after the
previous 7-day period ends.
For the codes describing add-on services (HCPCS codes G2076-G2080, G0137, and G0534-G0536), the
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date of service should reflect the date that service was furnished; however, if the OTP has chosen to apply a
standard weekly billing cycle, the date of service for codes describing add-on services may be the same as
the first day in the weekly billing cycle.
40.3 - Prescribing Individuals
(Rev. 4524: Issued; 02-14-20: Effective; 01-01-20: Implementation: 03-16-20)
OTPs should list the prescribing or medication ordering physician’s or other eligible professional’s National
Provider Identifier in Field 17 (the ordering/referring/other field) of the Form CMS–1500 (Health Insurance
Claim Form; 0938–1197) or the digital equivalent thereof.
50 – Institutional Opioid Treatment Program (OTP) Services – A/B MAC (A)
(Rev. 10521; Issued: 12-16-20; Effective: 01-01-21; Implementation: 01-04-21)
Medicare Part B coverage is available for outpatient Opioid Treatment Program services provided by hospitals,
CAHs, and Free-Standing Opioid Treatment Program facilities.
50.1 – Special Opioid Treatment Program Billing Requirements for Hospitals, Critical
Access Hospitals, and Free-Standing Opioid Treatment Program Facilities
(Rev. 10521; Issued: 12-16-20; Effective: 01-01-21; Implementation: 01-04-21)
Medicare Part B coverage is available for hospital outpatient Opioid Treatment Program services.
A. Billing Requirement
Section 1861(s)(2)(HH)(jjj) of the Act requires that opioid use disorder treatment services would include the
Food and Drug Administration (FDA)-approved opioid agonist and antagonist treatment medications, the
dispensing and administration of such medications (if applicable), substance use disorder counseling, individual
and group therapy, toxicology testing, and other items and services that the Secretary determines are appropriate.
Section 1861(s)(2)(HH)(jjj) defines OTPs as those that enroll in Medicare and are certified by the Substance
Abuse and Mental Health Services Administration (SAMHSA), accredited by a SAMHSA-approved entity, and
meet additional conditions as the Secretary finds necessary to ensure the health and safety of individuals being
furnished services under these programs and the effective and efficient furnishing of such services.
Hospitals and CAHs report condition code 89 in FLs 18-28 (or electronic equivalent) to indicate the claim is for
Opioid Treatment Program services. They must also report a revenue code and the charge for each individual
covered service furnished. In addition, hospital outpatient departments are required to report HCPCS codes.
CAHs are not required to report HCPCS code for this benefit.
Under component billing, hospitals are required to report a revenue code and the charge for each individual
covered service furnished under an opioid treatment program. In addition, hospital outpatient departments are
required to report HCPCS codes. Component billing assures that only those opioid treatment program services
covered under §1861(s)(2)(HH)(jjj) of the Act are paid by the Medicare program.
All hospitals are required to report condition code “89” in FLs 18-28 to indicate the claim is for opioid treatment
program services. Hospitals use bill type 013X and CAHs use bill type 085X. The following special procedures
apply:
Bills must contain an acceptable revenue code. They are as follows:
Revenue Code 	Description
0636 	Drugs Requiring Detailed Coding
0900 	Behavioral Health Treatment/Services
0914 	Individual Therapy
0915 	Group Therapy
0916 	Family Therapy
0918
0919
Behavioral Health/Testing
Other Behavioral Health Treatments
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0940
0944
General Classification
Drug Rehabilitation
0949
0953
Other Therapeutic Service
Chemical Dependency (Drug and
Alcohol)
Hospitals other than CAHs are also required to report appropriate HCPCS codes.
Edit to assure that HCPCS are present when the above revenue codes are billed and that they are valid HCPCS
codes. Do not edit for the matching of revenue code to HCPCS.
NOTE: Information regarding the Form CMS-1450 form locators that correspond with these fields is found in
Chapter 25 of this manual. See the ASC X12 837 Institutional Claim implementation guide for related guidelines
for the electronic claim.
B. Reporting of Service Units
Hospitals and Free-Standing facilities report the number of times the service or procedure, as defined by the
HCPCS code, was performed.
NOTE: Service units are not required to be reported for drugs and biologicals (Revenue Code 250).
C. Line Item Date of Service Reporting
Hospitals other than CAHs are required to report line item dates of service per revenue code line for opioid
treatment program claims. This means each service (revenue code) provided must be repeated on a separate line
item along with the specific date the service was provided for every occurrence. Line item dates of service are
reported in FL 45 “Service Date” (MMDDYY).
D. Special Requirements for Free-Standing Opioid Treatment Program Facilities
Section 1833 (s)(2)(HH)(jjj))) of the Act recognizes Free-Standing Opioid Treatment Program Facilities as
“providers of services” but only for furnishing Opioid Treatment Program services. Applicable provider ranges
are xx9900-xx9999 billed on a claim with a type of bill 087x. Other billing requirements (except condition code
“89” reporting) mentioned above for hospitals apply.
E. Payment
Section 1861 (s)(2)(HH)(jjj)) of the Act provides the statutory authority governing payment for opioid treatment
program services provided by a hospital or free-standing facility. A/B MAC(s) (A) make payment on a fee
schedule basis (see 30.8). CAH’s are paid at reasonable cost basis. The Part B deductible applies. There is no
PC/TC split for OTP billing. Only one (1) provider may bill for the services of the opioid treatment program,
either the facility or the practitioner, but not both.
F. Data for CWF and PS&R
Include revenue codes, HCPCS/CPT codes, units, and covered charges in the financial data section (fields 65a -
65j), as appropriate. Report the billed charges in field 65h, "Charges," of the CWF record.
Include in the financial data portion of the PS&R UNIBILL, revenue codes, HCPCS/CPT codes, units, and
charges, as appropriate.
G. Medical Review
The A/B MACs (A) follow medical review guidelines in Pub. 100-08, Medicare Program Integrity Manual.
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60 -OUD Diagnosis Code
(Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25)
Consistent with statutory provisions under sections 1861(s)(2)(HH), 1861(jjj)(1), and 1834 of the Act,
Medicare payment made under Part B to OTPs furnishing OUD treatment services must be for the treatment
of an OUD. Professional claims submitted on form CMS-1500 (or the electronic equivalent form 837P) and
institutional claims submitted on form CMS-1450 must include an OUD diagnosis. These diagnosis codes
must apply to HCPCS G-codes representing both the bundled payments for an episode of care and add-on
codes to the bundled payments. Applicable diagnosis codes for an OUD that must be submitted on claims
include ICD-10-CM codes in the F11 range for “disorders related or resulting from abuse or misuse of
opioids” : https://www.icd10data.com/ICD10CM/Codes/F01-F99/F10-F19/F11-.
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Transmittals Issued for this Chapter
Rev # 	Issue Date 	Subject 	Impl Date 	CR#
R13572CP 03/03/2026 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs (OTPs)
06/02/2026 	14347
R13198CP 04/30/2025 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs (OTPs)
03/25/2025 	13948
R13147CP 	03/28/2025 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs (OTPs) Rescinded and replaced by
transmittal 13198
03/25/2025 	13948
R13088CP 02/21/2025 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs (OTPs)- – Rescinded and replaced
by transmittal 13147
03/25/2025 	13948
R12418CP 12/21/2023 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs (OTPs)
01/24/2024 	13470
R11792CP 01/19/2023 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs and Additional Claims Modifier
for Audio-only Services
02/21/2023 	13062
R11219CP 01/27/2022 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs and New Modifier for Audio-only
Services
03/01/2022 	12545
R10665CP 03/16/2021 Updates to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual for Opioid
Treatment Programs (Manual Updates Only)
04/15/2021 	12161
R10521CP 12/16/2020 New Medicare National Uniform Billing Committee
(NUBC) Type of Bill (TOB), Condition Code and
implementing Billing Codes for Opioid Treatment
Programs
01/04/2021 	11856
R10266CP 08/06/2020 New Medicare National Uniform Billing Committee
(NUBC) Type of Bill (TOB), Condition Code and
implementing Billing Codes for Opioid Treatment
Programs – Rescinded and replaced by transmittal
10521
01/04/2021 	11856
R4524CP 	02/14/2020 Update to Medicare Benefit Policy Manual and
Medicare Claims Processing Manual Adding New
Chapters for Opioid Treatment Programs (Manual
Updates Only
03/16/2020 	11620
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