CMS Releases Guidance on Coverage Transition for ‘Dual Eligibles’ Receiving OTP Services

The Centers for Medicare & Medicaid Services (CMS) released an Informational Bulletin on Tuesday that provides guidance on coverage for Medicare and Medicaid dual-eligible beneficiaries who receive opioid treatment program (OTP) services. Revisions to the Physician Fee Schedule (CY 2020) allow for a new OTP bundled payment benefit under Medicare, which replaces Medicaid as the primary payer for OTP services for the dual-eligible population. The new benefit is effective January 1, 2020; however, not all OTP providers will have completed Medicare enrollment by that time. To assure continuity of patient care, states must pay OTP claims for Medicaid state plan covered services for Medicaid enrolled providers while Medicare enrollments are being completed. The new guidance from CMS provides information to state Medicaid agencies about strategies for continuing to pay for OTP services, including continuing to pay for claims for a specified period, and advising OTPs to submit claims only after their Medicare enrollment has been approved. CMS recommends that states communicate with Medicaid managed care plans that cover OTP benefits, as well as with providers to advise them to enroll in Medicare. If you have questions, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.