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Medicare Opioid Treatment Program Enrollment and Billing 2021 Updates

The CMS has modified coverage for the Medicare OTP beginning 1/1/2021.

The modifications include:

  • Coverage of OTP services in outpatient hospital setting
    • A CMS-855A provider enrollment application must be submitted and approved; see below for further information
  • Added coverage of the FDA-approved opioid antagonist medication naloxone for emergency treatment of opioid overdose, as well as overdose education
    • Two new HCPCS codes have been added to identify naloxone
      • Take-home supply of nasal naloxone (G2215)
      • Take-home supply of injectable naloxone (G2216)
  • OTPs may conduct periodic assessments via two-way interactive audio-video communication technology during the PHE for COVID-19
    • Applies to HCPCS code G2077, and add-on code G2080

We have received inquiries from providers about billing for OTP services in the outpatient hospital setting. Based on the questions received, we feel it is important to share the following facts to prevent claim errors resulting in denials:

  • SAMSHA certified health care organizations may enroll as either a Medicare Part A or Part B provider, but not as both.
  • If the provider is currently enrolled as a Medicare Part B OTP, submitting claims on the CMS-1500 claim form (or electronic equivalent), and the provider wants to continue this billing option; no action is necessary.
    • Continue to bill as you have been since your Medicare OTP enrollment effective date.
  • If the provider is currently enrolled as a Medicare Part B OTP, submitting claims on the CMS-1500 claim form (or electronic equivalent), and the provider wants to submit claims on the CMS-1450 (or electronic equivalent);
    • Must complete an initial Part A provider enrollment form CMS-855A (or via Internet-based PECOS) using the NPI for the OTP.
    • Once the Medicare Part A OTP application is approved, the Medicare Part B OTP enrollment is terminated. Then the provider may begin to submit claims using the CMS-1450.
    • The OTP effective date will remain the same as it was for the Part B OTP enrollment.
  • When enrolling as a Medicare OTP for the first time, you must determine if you should enroll under Medicare Part A or Medicare Part B.
    • Please use the instructions in the Medicare OTP Enrollment Fact Sheet to determine which application is best suited for your provider type.
    • Claims for OTP services cannot be submitted until you are enrolled as an approved Medicare OTP.

The MLN Fact Sheet® Opioid Treatment Programs (OTPs) Medicare Enrollment Fact Sheet and the MLN Fact Sheet® Opioid Treatment Programs (OTPs) Medicare Billing and Payment Fact Sheet include the 2021 modifications.

Posted 2/4/2021