In addition to the creation of the OTP benefit, the SUPPORT Act also mandates all states cover OTP in their Medicaid programs effective October 2020 subject to an exception process as defined by the Secretary.
For dually eligible beneficiaries (those enrolled in both Medicare and Medicaid) who get OTP services through Medicaid now, starting January 1, 2020, Medicare will be the primary payer for OTP services. CMS will issue guidance to states to clarify how Medicaid can pay OTP providers that are not yet enrolled in Medicare, so State Medicaid Agencies can uphold their responsibilities as the payer of last resort while promoting continuity of care for dually eligible beneficiaries. Briefly, Medicaid:
- Must pay for services delivered to these beneficiaries by OTP providers who are not yet enrolled in Medicare but are enrolled in Medicaid, to the extent the service is covered in the state plan.
- Will later recoup those Medicaid payments made to the OTP, back to the date the provider can begin billing Medicare (30 days prior to the effective date of the OTP’s Medicare enrollment), and the OTP will then bill Medicare for those services.
OTP providers should enroll in Medicare now to be able to bill Medicare for OTP services beginning January 1, 2020.