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The Minnesota Department of Human Services (DHS) is writing to provide an update on the implementation of Medicare-aligned rates for Opioid Treatment Program (OTP) services under Medical Assistance.
Current Status
DHS received federal approval (State Plan Amendment 24-0041) to implement Medicare OTP rates effective Jan. 1, 2025. However, due to the technical complexity of integrating 20 new billing codes and ensuring alignment with both federal Medicare requirements and Minnesota statute, implementation will not occur by Jan. 1, 2026.
Timeline
DHS is working with the Minnesota IT Services (MNIT) and internal systems teams to prioritize this implementation. We will provide updated timelines as they become available and will communicate implementation dates well in advance of go-live.
Retroactive Billing
DHS is exploring options to allow retroactive billing back to Jan. 1, 2026, for services provided during the implementation delay period. Additional guidance on retroactive billing procedures will be communicated when the system is ready to accept claims.
What This Means for Providers
- Continue billing using current procedures and codes.
- No action is required currently.
- Watch for future communications regarding implementation timeline and training opportunities.
- Questions can be directed to the State Opioid Treatment Authority.
DHS remains committed to implementing this enhanced benefit to support Minnesotans receiving OTP services. We appreciate your patience as we work to ensure a smooth and compliant implementation.
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Frequently Asked Questions
Q: Why is this taking so long? A: Implementing 20 new billing codes with complex bundling logic, frequency limitations and dual compliance requirements (Medicare and MN statute) requires extensive programming, testing and validation. We're committed to getting it right.
Q: Will providers lose money because of this delay? A: DHS is exploring retroactive billing options to Jan. 1, 2026, to minimize financial impact. Details will be communicated when available.
Q: Can providers bill Medicare rates now and get reimbursed later? A: No. Providers should continue using current billing procedures. The system is not yet configured to process the new codes.
Q: When will we know the actual go-live date? A: We will communicate updated timelines as they become available. Providers will receive advance notice before implementation.
Q: Does this affect tribal MOUD programs? A: Tribal programs can continue using existing codes (U9/M2, UB/M4). The new codes will only apply if a tribally licensed program decides to seek certification as an Opioid Treatment Program through DPT/SAMSHA and Drug Enforcement Administration.
Q: What should providers do right now? A: Nothing. Continue current billing practices and watch for official DHS communications.
Q: Will there be training before implementation? A: Yes. Comprehensive training will be provided to all OTP providers before go-live.
Q: Who approved these rates? A: CMS approved Minnesota's State Plan Amendment (24-0041) in December 2024. The delay is implementation-related, not approval-related.
For any additional questions, you can reach out to richard.moldenhauer@state.mn.us.
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