Skip to main content
U.S. flag

An official website of the United States government

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

Beta This is a new resource

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

Announced on  | Last Modified on  | Project Number: A-09-23-03002
Status
Completed
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

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.

TIMELINE

  • January 4, 2023
    Announced
  • October 2, 2025
    Complete

    Audit of Medicare Part B Opioid Use Disorder Treatment Services Provided by Opioid Treatment Programs—Bundled Payments and Telehealth Services has been marked as complete. This additional reports resulted in 3 recommendations.

REPORT PUBLISHED

Medicare Could Have Saved $301.5 Million if Bundled Payment Rates for Opioid-Use-Disorder Treatment Services Had Reflected Services Provided to Enrollees (A-09-23-03002)
  • For 100 sample items, bundled payments for 89 sample items were higher than the OIG-calculated payment amounts based on the OUD services actually provided by OTPs to enrollees.
  • Bundled payments generally exceeded OIG-calculated payment amounts because CMS’s methodology to determine bundled payment rates did not reflect the combination of specific OUD treatment services and the frequency of treatment services that OTPs provided to enrollees during an episode of care.
  • On the basis of our sample results, we estimated that Medicare could have saved $301.5 million (53 percent of $564.6 million in total payments) if the bundled payments developed by CMS had reflected the types and frequency of OUD treatment services provided to enrollees.

26-A-09-001.01 to CMS - Open Unimplemented
Update expected on 04/01/2026
We recommend that the Centers for Medicare & Medicaid Services take the following actions to align its bundled payment rates with OUD treatment services provided to enrollees during an episode of care, which could have saved Medicare an estimated $301,479,659 during our audit period, use the results of our audit or gather additional information on the combination of OUD treatment services and the frequency of each type of treatment service provided to Medicare enrollees, and consider revising its methodology for determining the nondrug component of the weekly bundled payment rates.

26-A-09-001.02 to CMS - Open Unimplemented
Update expected on 04/01/2026
We recommend that the Centers for Medicare & Medicaid Services take the following actions to align its bundled payment rates with OUD treatment services provided to enrollees during an episode of care, which could have saved Medicare an estimated $301,479,659 during our audit period, consider developing, within its statutory authority, additional HCPCS codes for the weekly bundles (e.g., codes reflecting services provided at lower frequencies).

26-A-09-001.03 to CMS - Open Unimplemented
Update expected on 04/01/2026
We recommend that the Centers for Medicare & Medicaid Services work with SAMHSA (or a designated agency) to perform monitoring activities to ensure OTPs have properly documented OUD treatment services in enrollees' treatment plans.

View in Recommendation Tracker
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Financial Stewardship Physician and Healthcare Practitioners Public Health Issues Quality of Care Substance Abuse Disorder
Target Groups
-
Financial Groups
Medicare B