CIB: Guidance for State Medicaid Agencies on Dually Eligible Beneficiaries Receiving Medicare Opioid Treatment Services Effective January 1, 2020


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Today the Centers for Medicare and Medicaid Services (CMS) issued an Informational Bulletin to provide guidance to states regarding coverage changes for dually-eligible beneficiaries (those enrolled in both Medicare and Medicaid) receiving opioid treatment services. Starting January 1, 2020, Medicare will begin paying for opioid treatment programs (OTPs) through bundled payments for opioid use disorder (OUD) treatment services, including medication-assisted treatment (MAT) medications, toxicology testing, and counseling as authorized under the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act).

For dually-eligible beneficiaries who receive OTP services through Medicaid now, starting January 1, 2020, Medicare will become the primary payer for OTP services. In order to be reimbursed by Medicare, OTP providers will need to be enrolled as a Medicare provider. It is possible that not all providers will have completed the Medicare enrollment process and be able to bill Medicare as primary payer by this date. In an effort to prevent any disruption in OTP treatment for dually-eligible beneficiaries, CMS is providing background information on the enrollment of providers for this benefit and clarifying options available for states to consider regarding coordination of benefits/third party liability under Medicaid.