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Series: Medicaid Claims for Opioid Treatment Program Services

Announced on  | Last Modified on  | Series Number: W-00-24-31523
Status
Completed
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

Medicaid is a significant source of coverage and funding for behavioral health treatment services, including treatment of substance abuse. Some Medicaid State agencies provide payment for Opioid Treatment Program (OTP) services. Services can be provided at freestanding and hospital-based OTPs. We will determine whether selected State agencies complied with certain Federal and State requirements when claiming Medicaid reimbursement for OTP services.

There are 2 projects in this series.

COMPLETED PROJECTS IN THIS SERIES (2)

Massachusetts

Project A-01-23-00002 • Completed on August 29, 2024

Washington

Project A-09-21-02001 • Completed on August 5, 2024

TIMELINE

  • February 17, 2021
    Series Number W-00-24-31523 Assigned
  • February 17, 2021
    Project Announced

    Washington - A-09-21-02001

  • July 28, 2023
    Project Announced

    Massachusetts - A-01-23-00002

  • August 5, 2024
    Project Complete - A-09-21-02001

    Washington has been marked as complete. This audit resulted in 10 recommendations.

  • August 29, 2024
    Project Complete - A-01-23-00002

    Massachusetts has been marked as complete. This audit resulted in 2 recommendations.

  • August 29, 2024
    Series Complete

    Medicaid Claims for Opioid Treatment Program Services has been marked as complete.

2 REPORT PUBLISHED

Massachusetts Opioid Treatment Program Services Met Many of the Federal and State Requirements (A-01-23-00002)

24-A-01-103.01 to CMS - Closed Implemented
Closed on 04/03/2025
We recommend the Massachusetts Executive Office of Health & Human Services follow up with the OTP providers to correct the three services that were not supported by the medical records.

24-A-01-103.02 to CMS - Closed Implemented
Closed on 04/03/2025
We recommend the Massachusetts Executive Office of Health & Human Services review its procedures designed to prevent OTP noncompliance with Federal and State requirements and make changes to improve documentation of counseling and more timely review of OTP treatment plans.

View in Recommendation Tracker

Opioid Treatment Programs in Washington State Did Not Fully Comply With Federal and State Requirements, Which May Have Put Medicaid Enrollees at Risk for Poor Treatment Outcomes (A-09-21-02001)

24-A-09-093.01 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs complete required tests for enrollee admissions and adequately document enrollee admissions.

24-A-09-093.02 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document treatment plans.

24-A-09-093.03 to CMS - Closed Implemented
Closed on 10/02/2025
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs provide take-home medications in accordance with Federal and State requirements.

24-A-09-093.04 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document opioid treatment services.

24-A-09-093.05 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document the results of drug screens.

24-A-09-093.06 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contractedMCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document checks of Washington State PDMP prescription data to identify enrollees' prescriptions.

24-A-09-093.07 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document enrollee assessments.

24-A-09-093.08 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs demonstrate through documentation that treatment plans and progress notes are reviewed by qualified staff.

24-A-09-093.09 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs complete and adequately document annual medical examinations.

24-A-09-093.10 to CMS - Closed Acceptable Alternative
Closed on 04/14/2026
We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs identify in the enrollee records the staff members who provided SUD assessments.

View in Recommendation Tracker
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Managed Care Substance Abuse Disorder
Target Groups
-
Financial Groups
Medicaid