Billing & Payment
Billing & Payment
COVID-19: CMS Allowing Audio-Only Calls for OTP Therapy, Counseling, and Periodic Assessments
CMS revised regulation text to allow audio-only telephone calls for the therapy and counseling portions of the weekly bundles and the add-on code for additional counseling or therapy (HCPCS code G2080) for beneficiaries with opioid use disorders, provided all other requirements are met. Providers may conduct the periodic patient assessments (HCPCS code G2077) via two-way interactive audio-video communication technology or by telephone only in cases where the beneficiary does not have access to two-way interactive technology.
This change, effective March 1, 2020, is necessary so beneficiaries without access to interactive audio-video communication technology can continue receiving these important services.
This will apply for the duration of the public health emergency for the COVID-19 pandemic. OTPs should continue to use Place of Service code 58 on claims for all OTP services, including those furnished using audio-video or audio-only communication technology.
The CY2022 Physician Fee Schedule proposed rule includes a proposal for OTPs to provide counseling and therapy services via audio-only technology, such as telephone calls, after the conclusion of the Public Health Emergency when audio/video communication is not available to the patient. CMS proposes a requirement that OTPs:
- Use a service-level modifier for audio-only services billed using the counseling and therapy add-on code
- Document in the medical record the rationale for providing a service using audio-only technology for program integrity purposes
We encourage OTPs to read the proposed rule and submit formal comments by September 13, 2021.
As of January 1, 2020, Medicare pays enrolled Opioid Treatment Programs (OTPs) bundled payments based on weekly episodes of care for services including:
- FDA-approved treatment medications for the treatment of OUD
- The dispensing and administration of such medications (if applicable)
- Substance use counseling
- Individual and group therapy
- Toxicology testing
Medicare will also adjust payments for the bundled payment amount for intake activities and periodic assessments, which are required by SAMHSA, as well as for additional counseling and therapy, and take-home supplies of medications.
There is NO copayment for OTP services for people with Medicare.
New for CY 2021
- New covered services include FDA-approved opioid antagonist medications, specifically naloxone, for emergency treatment of opioid overdose, as well as overdose education
- New codes for nasal and injectable naloxone
- OTPs may conduct periodic assessments via two-way interactive audio-video communication technology
Review the OTP Medicare Billing & Payment Fact Sheet (PDF) to learn about:
- Covered opioid use disorder (OUD) Treatment Services
- Coding and submitting claims for OTP services
- Payment and remittance advice (RA)
If you’re a clinician, visit the office-based OUD treatment services webpage for more information on billing. Clinicians can’t use OTP codes to bill for office-based treatment.
The CY 2020 (PDF) and CY 2021 (PDF) National Final Unadjusted Payment Rates for OTPs documents describe OTP HCPCS G-codes, bundled payments, and the total unadjusted payment assigned to each rate code.
CMS adjusts the non-drug component of the OTP bundled payments for geographic locality so payment rates will vary depending on the OTP’s location. CMS also geographically adjusts the add-on payments for non-drug services (i.e., intake activities, periodic assessments, additional counseling and therapy).
Identifying CY2021 Locality-Specific Payment Rates
1. In the Locality Key (PDF) (PDF) document, find the locality and MAC numbers assigned to your OTP based on the State/Fee Schedule Area/County location of your practice.
2. In the CY 2021 National Final Unadjusted Payment Rates for OTPs (PDF) document, find the HCPCS code for the service of interest.
3. In the Locality Adjusted Rates (PDF) document, find your locality and corresponding MAC numbers along with the HCPCS code to find the geographically-adjusted payment rate. We updated the CY2021 locality-adjusted rates for OTP services to reflect the Geographic Practice Cost Index work floor, which the Consolidated Appropriations Act, 2021 extended through Jan. 1, 2024.