Audit of Medicare Part B Opioid Use Disorder Treatment Services Provided by Opioid Treatment Programs-Bundled Payments and Telehealth Services

Substance use disorders involving drugs or alcohol can cause serious health problems and even death. Medication for substance use disorders, including opioid use disorder (OUD), is used to sustain recovery and prevent overdoses. Currently, there are three Food and Drug Administration (FDA)-approved medications to treat OUD: buprenorphine, methadone, and naltrexone. Treatment for OUD is provided in several settings, including freestanding opioid treatment programs (OTPs).

Section 2005 of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) established a new Medicare Part B benefit for OUD treatment services furnished by OTPs. CMS implemented this benefit for services furnished on or after January 1, 2020, as required by the SUPPORT Act. Section 1834(w)(2) of the Social Security Act authorized the HHS Secretary to implement the Medicare OTP benefit by using one or more payment bundles. Under section 1861(jjj) of the Social Security Act, OUD treatment services include FDA-approved treatment medication, dispensing and administration of treatment medication, substance use counseling, individual and group therapy, toxicology testing, and other items and services that the HHS Secretary determines are appropriate.

We will review the OUD treatment services that were reimbursed under the bundle payments provided to people enrolled in Medicare. We will determine the types, delivery methods (i.e., in person or via telehealth), and frequency of OUD treatment services provided to Medicare enrollees by OTPs that received bundled payments. We will compare the bundled payments for OUD treatment services with the reimbursement amount of the actual OUD treatment services if the services were not part of the bundled payment. We will also determine whether these services complied with certain Medicare requirements.

Announced or Revised	Agency	Title	Component	Report Number(s)	Expected Issue Date (FY)
December 2022	Centers for Medicare and Medicaid Services	Audit of Medicare Part B Opioid Use Disorder Treatment Services Provided by Opioid Treatment Programs-Bundled Payments and Telehealth Services	Office of Audit Services	WA-23-0006 (W-00-23-35895)	2025