U.S. Department of Health and Human Services 
Office of Inspector General 
 
Data Brief 
 
December 2021, OEI-02-20-00390 
 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat 
Their Opioid Use Disorder 
Why OIG Did This Review 
Key Takeaways 
Opioid-related overdose deaths in the United States are at an all-
Opioid use disorder is a chronic  time high, reaching an estimated 70,000 in 2020.1  As the country 
disease that can be treated with  continues to struggle with the opioid crisis, it is critical that 
medication.   people with opioid use disorder have access to treatment.  The 
coronavirus disease 2019 (COVID-19) pandemic has made this 
Yet less than 16 percent of 
beneficiaries received medication to  need even more urgent, particularly because the toll it has taken 
treat their opioid use disorder.  on beneficiaries mental health and the extent to which it has 
increased the number of beneficiaries with opioid use disorder 
Even fewer beneficiaries received 
are not yet known. 
both medication and behavioral 
therapy to treat their opioid use 
Opioid use disordera problematic pattern of opioid use that 
disorder. 
leads to clinically significant impairment or distressis a chronic 
Beneficiaries in Florida, Texas,  disease that can be treated with certain medications.  These 
Nevada, and Kansas were less likely 
medications have been shown to decrease illicit opioid use and 
to receive medication for their opioid 
opioid-related overdose deaths.  The combination of these 
use disorder than those nationwide. 
medications with behavioral therapy is referred to as medication-
Furthermore, Asian/Pacific Islander,  assisted treatment.   
Hispanic, and Black beneficiaries 
were less likely to receive medication  Medicare plays an important role in ensuring that beneficiaries 
than White beneficiaries.   with opioid use disorder have access to treatment.  Three 
medications are approved for the treatment of opioid use 
 
disorder: buprenorphine, methadone, and naltrexone.  Beneficiaries can receive these drugs in office-
based settings or from opioid treatment programs.  To prescribe or administer buprenorphine in office-
based settings, providers must receive a waiver through the Substance Abuse and Mental Health 
Services Administration (SAMHSA).  In addition, opioid treatment programs are the only outpatient 
settings allowed to administer and dispense methadone.  
How OIG Did This Review 
We analyzed claims from Medicare Parts B, C, and D to determine the extent to which beneficiaries 
diagnosed with opioid use disorder received medication and behavioral therapy to treat their opioid 
use disorder through Medicare in 2020.   
What OIG Found 
About 1 million Medicare beneficiaries were diagnosed with opioid use disorder in 2020.  Yet less than 
16 percent of these beneficiaries received medication to treat their opioid use disorder, raising concerns 
that beneficiaries face challenges accessing treatment.  Furthermore, less than half of the beneficiaries 
who received medication to treat their opioid use disorder also received behavioral therapy.  These 
services may be provided in-person or via telehealth; however, the full extent to which beneficiaries use 
  telehealth for behavioral therapy is unknown, as Medicare does not require opioid treatment programs 
to report this information.   
In addition, beneficiaries in Florida, Texas, Nevada, and Kansas were less likely to receive medication to 
treat their opioid use disorder than beneficiaries nationwide.  Furthermore, Asian/Pacific Islander, 
Hispanic, and Black beneficiaries were less likely to receive medication than White beneficiaries.  Older 
beneficiaries and those who did not receive the Part D low-income subsidy were also less likely to 
receive medication to treat their opioid use disorder.   
What OIG Recommends  
These findings show a need to increase the number of Medicare beneficiaries receiving treatment for 
opioid use disorder.  Accordingly, we recommend that the Centers for Medicare & Medicaid Services 
(CMS) take these steps: (1) conduct additional outreach to beneficiaries to increase awareness about 
Medicare coverage for the treatment of opioid use disorder; (2) take steps to increase the number of 
providers and opioid treatment programs for Medicare beneficiaries with opioid use disorder; (3) assist 
SAMHSA by providing data about the number of Medicare beneficiaries receiving buprenorphine in 
office-based settings and the geographic areas where Medicare beneficiaries remain underserved; 
(4) take steps to increase the utilization of behavioral therapy among beneficiaries receiving medication 
to treat opioid use disorder; (5) create an action plan and take steps to address disparities in the 
treatment of opioid use disorder; and (6) collect data on the use of telehealth in opioid treatment 
programs.  CMS concurred with four of our recommendations and did not explicitly indicate whether it 
concurred with the other two recommendations. 
 
  Primer: Treatment of Opioid Use Disorder 
Medications to Treat Opioid Use Disorder 
Opioid use disorder is a chronic disease that can be treated with certain medications.  These 
medications have been proven to decrease the risk of overdose mortality and improve quality of life.2  
The combination of these medications with behavioral therapy is referred to as medication-assisted 
treatment (MAT).  Throughout this report, we refer to these medications as MAT drugs.3    
Three drugs are currently approved for the treatment of opioid use disorder.   
  Buprenorphine is a Schedule III controlled substance that suppresses opioid withdrawal symptoms 
by relieving cravings.4  To prescribe or administer buprenorphine in office-based settings, providers 
must obtain a waiver through the Substance Abuse and Mental Health Services Administration 
(SAMHSA).5    
  Methadone is a Schedule II controlled substance that reduces opioid cravings by blunting or 
blocking the effects of opioids.  Methadone is highly regulated; only opioid treatment programs are 
allowed to administer or dispense methadone for treatment of opioid use disorder in outpatient 
settings.6  Patients typically go in-person each day to receive their dose of methadone.7  Medicare 
began covering methadone for MAT at opioid treatment programs in 2020.8 
  Naltrexone works by blocking the opioid receptors in the brain, which is reported to reduce opioid 
cravings.9  Unlike buprenorphine and methadone, naltrexone is not a controlled substance and can 
be prescribed or administered by any qualified health care provider.  Patients must go through full 
detoxification before beginning naltrexone.   
 
Behavioral Therapy to Treat Opioid Use Disorder  
Behavioral therapysuch as individual or group therapyis recommended for patients receiving 
medication to treat opioid use disorder.  Opioid treatment programs are required to offer behavioral 
therapy.10  Behavioral therapy is not required when medication is provided in an office-based setting.   
 
Medicare Coverage of Treatment for Opioid Use Disorder in Outpatient Settings 
Beneficiaries can receive MAT drugs in office-based settings or from opioid treatment programs.  
In office-based settings, beneficiaries either receive prescriptions for medications that they fill at 
pharmacies or their healthcare providers directly administer the MAT drugs.  Medicare pays for these 
medications differently depending on where beneficiaries receive them.  Beneficiaries may also receive 
these medications through other sources, such as by paying out-of-pocket. 
Behavioral therapy that beneficiaries receive in office-based settings or at opioid treatment programs is 
covered by Medicare Part B or Part C.  Providers in office-based settings can bill for these services 
individually or use a bundled payment code that covers behavioral therapy and care coordination.  
Opioid treatment programs are paid through bundled payments.
   
RESULTS
 
Just over 1 million Medicare beneficiaries had a diagnosis of 
opioid use disorder in 2020 
In 2020, just over 1 million Medicare beneficiaries1,055,809 in totalhad a 
diagnosis of opioid use disorder.11  Opioid use disorder is a problematic pattern of 
opioid use that leads to clinically significant impairment or distress and is sometimes 
referred to as opioid addiction.  It is a chronic disease that may cause people to seek 
opioids compulsively or in ways that they find difficult to control despite harmful 
consequences.   
Diagnosing opioid use disorder requires a thorough evaluation that may include 
checking a patients history of opioid prescriptions or testing a patients urine for 
drugs.12  To receive a diagnosis, a patient must meet two or more diagnostic criteria, 
such as craving opioids or often taking opioids in larger amounts or over a longer 
period than intended.13  See Appendix A for a complete list of diagnostic criteria.   
Yet less than 16 percent of these beneficiaries received 
medication to treat their opioid use disorder  
Medications to treat opioid use disordersometimes called medication-assisted 
treatment (MAT) drugscan decrease illicit opioid use and opioid-related overdose 
deaths.14  Only 167,734 of the more 
Exhibit 1: Less than 16 percent of 
than 1 million beneficiaries with 
beneficiaries with opioid use  
opioid use disorderless than 
16 percentreceived medication to  disorder received medication to  
treat their opioid use disorder in  treat this condition through Medicare.  
2020 through Medicare.15  See 
Exhibit 1.  They accounted for fewer 
15.9%
than 1 in 6 of all Medicare 
beneficiaries with opioid use 
disorder.     
Each of these 167,734 beneficiaries 
received at least one of the three 
84.1%
approved drugs to treat opioid use 
disorder: buprenorphine, 
methadone, and naltrexone.  
The Food and Drug Administration  Source: OIG analysis of Medicare claims data, 2021. 
(FDA) recommends that all three of 
these drugs be available to all patients because certain medications may be more 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 4  appropriate for some patients than others.16  See Appendix B for the percentage of 
beneficiaries who received each type of medication.    
The low proportion of beneficiaries with opioid use disorder receiving MAT drugs 
through Medicare raises concern.  MAT drugs may not be medically necessary for all 
of these beneficiaries.  However, this low proportion may indicate that beneficiaries 
have challenges accessing treatment for opioid use disorder despite Medicares new 
coverage of opioid treatment programs in 2020.   
These challenges may be due to a variety of reasons.  Researchers have found that 
there are gaps between the number of providers who are authorized to treat patients 
with opioid use disorder with medication and the number of patients who need 
care.17  Furthermore, individuals may also avoid seeking treatment due to stigma 
associated with opioid use disorder.18  Lastly, beneficiaries may have delayed or 
avoided seeking health care during the COVID-19 pandemic.19    
Beneficiaries most commonly received medication to treat their 
opioid use disorder that was prescribed or administered in health 
care providers offices 
About 12 percent of the beneficiaries 
Exhibit 2: SAMHSAs Buprenorphine 
with opioid use disorder received MAT 
Waiver Program 
drugs that were prescribed or 
administered in their health care    Only health care providers who have 
providers officesi.e., in office-based 
received a buprenorphine waiver from 
settings.  This represents a total of 
the Substance Abuse and Mental 
130,502 Medicare beneficiaries and 
Health Services Administration 
includes both beneficiaries whose 
(SAMHSA) are authorized to prescribe 
providers ordered prescriptions that 
buprenorphine in office-based settings. 
were filled at pharmacies and 
beneficiaries whose providers directly    The waiver program is intended to 
administered their medications (e.g.,  increase access to quality 
long-acting injectable MAT drugs).   buprenorphine treatment from trained 
providers while also preventing drug 
The majority of these beneficiaries 
diversion. 
received buprenorphine.  About 
95 percent of these beneficiariesa    To qualify for a waiver, providers must 
total of 123,745who received MAT  have completed approved training.* 
drugs in office-based settings received 
  Providers are limited in the number of 
buprenorphine.20  As noted earlier, 
patients they may treat.   
methadone for the treatment of opioid 
use disorder is not available in office- * Since April 2021, providers who plan to treat up to  
30 patients have been exempt from some of the 
based settings. 
requirements related to training, counseling, and other 
services.  
Providers are required to obtain 
 
waivers to prescribe or administer 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 5  buprenorphine in office-based settings, and they are limited in the number of patients 
they may treat.  See Exhibit 2.  As a result, beneficiaries may have had limited access 
to these providers.21  OIG has previously raised concerns about the lack of access to 
providers with a buprenorphine waiver.  In 2018, 40 percent of all counties in the 
United States did not have a single provider with a buprenorphine waiver.22  
Furthermore, areas where access to MAT drugs was considered most critical did not 
always have providers. 
In most instances, beneficiaries who received buprenorphine in office-based settings 
had this medication covered by Part D.23  In rare instances, it was covered by Part B or 
Part C.24   
A smaller proportion of beneficiaries who received MAT drugs in office-based 
settings received naltrexone.  About 6 percent of beneficiariesa total of 8,257
who received MAT drugs in office-based settings received naltrexone.  In most 
instances, beneficiaries naltrexone was covered by Part D.25  Rarely, it was covered by 
Part B or Part C.26   
Less commonly, beneficiaries 
Exhibit 3: Opioid Treatment 
received medication to treat  Programs 
their opioid use disorder from 
  Opioid treatment programs can 
opioid treatment programs  provide all three MAT drugs
buprenorphine, methadone, and 
In 2020, less than 4 percent of the 
naltrexoneto treat patients with 
beneficiaries with opioid use disorder 
opioid use disorder.  Importantly, 
received MAT drugs from opioid 
they are the only entities that can 
treatment programs.  This represents 
provide methadone in outpatient 
39,602 beneficiaries with opioid use 
settings.   
disorder.  See Exhibit 3.   
  These programs are required to 
A low number of beneficiaries may have 
provide adequate medical, 
received MAT drugs from opioid 
counseling, vocational, educational, 
treatment programs because Medicare 
and other assessment and 
only began covering services provided at 
treatment services.   
opioid treatment programs in 2020.27  In 
addition, beneficiaries may be    A patient receiving methadone 
experiencing difficulties accessing opioid  typically must visit an opioid 
treatment programs for other reasons  treatment program each day to 
such as geographic limitations or patient  receive a dose.  Over time, the 
admission requirements.28  The need to  patient may be able to receive 
travel to opioid treatment programs may  unsupervised take-home doses.  
hinder access, as patients often must 
  Medicare began covering opioid 
make daily trips, which can be 
treatment programs in 2020.  It 
burdensome.29  Furthermore, more stigma 
provides reimbursements through 
is attached to opioid treatment programs 
weekly bundled payments.  
and the use of methadone than the use of 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 6  buprenorphine, and this stigma may impact the likelihood that beneficiaries will seek 
treatment.30   
The vast majority of these beneficiaries received methadone.  A total of 
96 percent of beneficiaries who received MAT drugs from opioid treatment 
programs38,170 in allreceived methadone.31  Importantly, opioid treatment 
programs are the only entities that can provide methadone for the treatment of 
opioid use disorder in outpatient settings.  Fewer beneficiaries received 
buprenorphine.  Rarely, beneficiaries received long-acting injectable naltrexone.  See 
Exhibit 4.   
Exhibit 4: Beneficiaries who received treatment from opioid treatment 
programs most commonly received methadone. 
MAT Drug     Beneficiaries  
Methadone  38,170 
 
Buprenorphine  2,164 
Injectable Naltrexone  26 
Total  39,602* 
 
* Of these beneficiaries, 758 beneficiaries received more than 1 type of MAT drug.  
Source: OIG analysis of Medicare claims data, 2021. 
 
Almost all of the beneficiaries who received buprenorphine at opioid treatment 
programs received buprenorphine tablets.32  Rarely, they received long-acting 
injectable buprenorphine.  See Appendix B for more information.  
Less than half of the beneficiaries who received medication to 
treat their opioid use disorder also received behavioral therapy  
Forty-seven percent of all beneficiaries 
Exhibit 5: Only 47 percent of  
who received medication to treat their 
beneficiaries who received MAT drugs 
opioid use disorder also received 
also received behavioral therapy.  
behavioral therapy through Medicare.  
See Exhibit 5.  This amounted to a total 
of 78,760 beneficiaries.     
Behavioral therapy can be beneficial for 
people with opioid use disorder, as these 
47%
services can increase patient engagement,  53%
modify patient behavior, and address any co-
occurring mental health disorders.33  Examples 
of behavioral therapy include individual and 
group therapy.  SAMHSA recommends 
Source: OIG analysis of Medicare claims data, 2021. 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 7  including behavioral therapy in treatment as needed.34   
Less than one-third of the beneficiaries who received medication 
in an office-based setting also received behavioral therapy. 
Less than one-third of the 130,502 beneficiaries who received MAT drugs in office-
based settings also received behavioral therapy.  This represents 39,957 beneficiaries.  
Most of these beneficiaries37,151received individual psychotherapy and 
7,275 received group psychotherapy.35   
Although recommended by SAMHSA, providers who prescribe or administer MAT 
drugs in office-based settings are not required by SAMHSA to provide behavioral 
therapy to beneficiaries.36  This is because the benefits of medication such as reducing 
the risk of overdose and death are far greater than the risks associated with not 
receiving behavioral therapy.37   
The low proportion of beneficiaries receiving behavioral therapy raises additional 
concern as beneficiaries with opioid use disorder often have co-occurring mental 
health disorders.38 
About half of these beneficiaries used telehealth to receive behavioral therapy.  
Telehealth is seen as an important tool in the treatment of opioid use disorder and 
other substance use disorders because it reduces barriers in access to treatment.  
Approximately half of the 39,957 beneficiariesa total of 21,390used telehealth for 
at least 1 behavioral therapy service. 
In 2019, Medicare began allowing the use of telehealth for the treatment of substance 
use disorders and co-occurring mental health disorders with fewer restrictions than 
most other services.39  In most instances, real time and two-way audio visual 
communication is required.  During the COVID-19 pandemic, further expansions of 
telehealth occurred that allowed behavioral therapy to be delivered using audio-only 
communication.40 
A small number of beneficiaries received behavioral therapy billed to Medicare 
through newly established office-based bundled payments for opioid use 
disorder.  Medicare established bundled payments that combine behavioral health 
therapy and care coordination for the treatment of opioid use disorder in office-based  
settings in 2020.41  However, only 1,823 beneficiaries received behavioral therapy that 
was billed to Medicare using these newly established bundled payments. 
The relatively low utilization of these bundled payment codes may be because these 
codes are new.  These codes only became available to bill beginning in January 2020.  
It may also indicate that the bundled payments need to be reassessed. 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 8  Beneficiaries who received MAT drugs from opioid treatment 
programs also received behavioral therapy, as required 
Medicare beneficiaries who received MAT drugs from an opioid treatment program in 
2020 also received behavioral therapy to address their opioid use disorder.  Opioid 
treatment programs are required to provide behavioral therapy to all patients.42   
These services may be provided in-person or via telehealth.  During the COVID-19 
pandemic, Medicare also allowed for audio-only calls for behavioral health and 
certain other services from opioid treatment programs.  
However, the extent to which beneficiaries received behavioral health and other 
services via telehealth from opioid treatment programs cannot be determined, as 
CMS does not require opioid treatment programs to report this information on 
Medicare claims.43  In contrast, CMS does require other types of providers such as 
physicians to report when services are delivered via telehealth on Medicare claims.44   
Beneficiaries in Florida, Texas, Nevada, and Kansas were two to 
three times less likely to receive medication to treat their opioid 
use disorder than beneficiaries nationwide 
Beneficiaries in Florida, Texas, Kansas, and Nevada were two to three times less 
likely to receive medication to treat their opioid use disorder.  In each of these 
States, fewer than 8 percent of the beneficiaries with opioid use disorder received 
MAT drugs, compared to about 16 percent nationwide.  See Exhibit 6.   
Florida and Texas had the lowest percentage of beneficiaries.  In Florida, just 
5 percent of beneficiaries with opioid use disorder received MAT drugs through 
Medicare.  In Texas, only 6 percent did so.  Nevada (7 percent) and Kansas (7 percent) 
also had low percentages.  See Exhibit 6 and Appendix C.    
Notably, Florida, Texas, and Nevada also had very low numbers of providers who have 
buprenorphine waivers and are authorized to prescribe buprenorphine to treat opioid 
use disorder.  Each of these States had fewer than 45 providers with a buprenorphine 
waiver per 1,000 Medicare beneficiaries with opioid use disorder.  These States, along 
with Mississippi, Oklahoma, Louisiana, and Alabama were the seven States with the 
lowest numbers of providers in the country.45  OIG has previously raised concerns that 
many areas of the country have limited access to providers who are authorized to 
prescribe buprenorphine.46   
Furthermore, beneficiaries in Texas and Florida rarely received treatment from opioid 
treatment programs.  Less than 1 percent of the beneficiaries with opioid use disorder 
in these States received MAT drugs from an opioid treatment program, compared to 
4 percent nationwide.  The percentage was equally low in South Dakota, Idaho, 
Wyoming, Nebraska, and North Dakota.  These States tended to have low numbers of 
opioid treatment programs enrolled in Medicare relative to the number of 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 9  beneficiaries with opioid use disorder.  There are no opioid treatment programs 
enrolled in Medicare in South Dakota and Wyoming.47   
It is important that beneficiaries have access to opioid treatment programs because 
they are the only source of methadone for MAT in outpatient settings.   
Exhibit 6: Beneficiaries in Florida, Texas, Nevada, and Kansas were the 
least likely to receive medication for their opioid use disorder. 
Source: OIG analysis of Medicare claims data, 2021. 
Asian/Pacific Islander, Hispanic, and Black beneficiaries were 
less likely to receive medication to treat their opioid use 
disorder than White beneficiaries  
There are notable racial and ethnic disparities in medication for opioid use disorder.  
Lower percentages of Asian/Pacific Islander, Black, and Hispanic beneficiaries received 
MAT drugs to treat their opioid use disorder than White beneficiaries.48  About 
10 percent of Asian/Pacific Islander, 12 percent of Hispanic, and 13 percent of Black 
beneficiaries received medication compared to 17 percent of White beneficiaries.  See 
Exhibit 7. 
In addition, differences exist in the settings from which beneficiaries received MAT 
drugs to treat their opioid use disorder.  Asian/Pacific Islander, Hispanic, and Black 
beneficiaries were less likely to receive MAT drugs in office-based settings than White 
beneficiaries.  Receiving medication in an office-based setting can be less 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 10  burdensome than receiving it from an opioid treatment program.49  Beneficiaries who 
are prescribed buprenorphine in office-based settings can fill these prescriptions at 
pharmacies.   
Furthermore, Asian/Pacific Islander, Hispanic, and Black beneficiaries were more likely 
to receive MAT drugs from opioid treatment programs than White beneficiaries.  
Patients who receive methadone from opioid treatment programs typically must 
travel each day to programs to receive their doses.50  In addition to being less 
convenient, more stigma is generally attached to methadone than buprenorphine.51  
 
Exhibit 7: Asian/Pacific Islander, Hispanic, and Black beneficiaries were less 
likely than White beneficiaries to receive medication to treat their opioid use 
disorder.*  
Asian/Pacific
3.7% 6.5% 10.1% 
Islander
Hispanic 4.5% 7.7% 12.0% 
Black 4.7% 8.3% 12.8%
 
White 3.4% 13.8% 17.0% 
Opioid Treatment Programs Office-Based Settings
* The totals are less than the sum because some beneficiaries received drugs in both settings. 
Source: OIG analysis of Medicare claims data, 2021. 
Older beneficiaries and those not receiving the Part D low-
income subsidy were also less likely to receive medication to 
treat their opioid use disorder  
Older beneficiaries were less likely to receive medication than younger 
beneficiaries to treat their opioid use disorder.  Older beneficiariesi.e., those 
aged 65 and olderwere far less likely to receive MAT drugs than those under the 
age of 65.  Younger beneficiaries often qualify for Medicare because of disability and 
account for almost half of beneficiaries with opioid use disorder.    
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 11  Just 8 percent of beneficiaries with opioid use disorder over the age of 65 received 
MAT drugs, compared to 25 percent of those under 65a 3-fold difference.  See 
Exhibit 8. 
Exhibit 8: Older beneficiaries were 3 times less likely to receive medication 
to treat their opioid use disorder than younger beneficiaries.   
8%   25%  
of beneficiaries  of beneficiaries 
65 and older  younger than 65  
received   received 
medication  medication 
Source: OIG analysis of Medicare claims data, 2021. 
Older beneficiaries were less likely to receive MAT drugs than younger beneficiaries, 
regardless of the State they lived in.  In every State, a lower percentage of older 
beneficiaries received MAT drugs than younger beneficiaries. 
Beneficiaries not receiving the Part D low-income subsidy were less likely to 
receive medication to treat their opioid use disorder than those receiving the 
subsidy.  Some beneficiaries who have limited income and assets receive assistance 
with paying for Part D premiums and cost-sharing.  This assistance is called the Part D 
low-income subsidy.52  Beneficiaries who did not receive this subsidy were less likely 
to receive MAT drugs.  
Beneficiaries who did not receive the low-income subsidy were three times less likely 
to receive MAT drugs through Medicare than beneficiaries who did receive it.  In total, 
just 8 percent of beneficiaries who did not receive the subsidy received MAT drugs, 
compared to 23 percent of beneficiaries who did receive the subsidy.  See Exhibit 9. 
Exhibit 9: Beneficiaries not receiving the Part D low-income subsidy 
were almost 3 times less likely to receive medication to treat their 
opioid use disorder than those receiving the subsidy. 
8%   23%  
of beneficiaries who  of beneficiaries who  
did not receive the  did receive the  
Part D subsidy   Part D subsidy  
received medication  received medication 
Source: OIG analysis of Medicare claims data, 2021. 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 12  Part D copayments may be a barrier for some beneficiaries receiving MAT drugs in 
office-based settings.  Beneficiaries who did not receive the low-income subsidy paid 
an average of $324 in 2020 for Part D copayments for MAT drugs.  A small number of 
beneficiaries paid much higher amounts.  About 1,500 beneficiaries paid more than 
$1,300 in 2020 for Part D copayments for MAT drugs.  Copayments are not a barrier 
for treatment from opioid treatment programs.  Currently, there are no copayments 
for drugs and services from opioid treatment programs.53  
Beneficiaries who did not receive the Part D low-income subsidy are also less likely 
than beneficiaries who did receive the subsidy to receive MAT drugs, regardless of 
their age or State.   
Female beneficiaries were also less likely to receive medication to treat their 
opioid use disorder than male beneficiaries.  A lower percentage of female 
beneficiaries with opioid use disorder received MAT drugs than male beneficiaries.  In 
total, 13 percent of female and 19 percent of male beneficiaries received medication 
to treat their opioid use disorder in 2020. 
 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Results | 13   
RECOMMENDATIONS 
 
 
Access to treatment for opioid use disorder is increasingly important as concerns 
about the opioid epidemic and the increase in overdose deaths heighten.  Medicare 
plays a key role in ensuring that beneficiaries have access to treatment.   
Yet less than 16 percent of beneficiaries are receiving medication through Medicare 
to treat their opioid use disorder that has been shown to decrease illicit opioid use 
and opioid-related overdose deaths.  Even fewer beneficiaries are receiving both 
medication and behavioral therapy through Medicare. 
In addition, despite Medicare being a national program, there is significant variation 
among States in the percentages of beneficiaries receiving medication to treat their 
opioid use disorder.  This may be due in part to low numbers of providers with a 
buprenorphine waiver and opioid treatment programs available to treat patients with 
opioid use disorder in some States. 
There are also notable racial and ethnic disparities reflected in the use of medication 
for opioid use disorder.  Asian/Pacific Islander, Hispanic, and Black beneficiaries are 
less likely to receive medication to treat their opioid use disorder than White 
beneficiaries.  These groups are also less likely to receive medication in office-based 
settings which have less stigma attached and are more convenient than opioid 
treatment programs.  
Together, these findings show a need to increase the number of Medicare 
beneficiaries receiving treatment for opioid use disorder.  The Department of Health 
and Human Services (HHS) and CMS have recently taken several steps to expand 
access to treatment.  For example, in April 2021 HHS released new practice guidelines 
that exempt eligible providers seeking a buprenorphine waiver from certain training 
requirements as long as they are treating 30 or fewer patients with buprenorphine.54  
Furthermore, CMS improved the information available to beneficiaries about 
Medicare coverage for the treatment of opioid use disorder.  In addition, CMS now 
requires that providers screen Medicare beneficiaries for potential opioid use disorder 
during annual wellness visits and initial preventative physical exams.55  CMS also 
established an additional payment when medication for the treatment of opioid use 
disorder is initiated in an emergency department.56  CMS should build on these 
efforts, address the continuing gap in treatment, and ensure that Medicare 
beneficiaries with opioid use disorder receive needed treatment.   
   
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Recommendations | 14  We recommend that CMS: 
Conduct additional outreach to beneficiaries to increase awareness about 
Medicare coverage for the treatment of opioid use disorder  
CMS plays an important role in increasing awareness among beneficiaries about 
Medicare coverage for the treatment of opioid use disorder.  CMS should take 
additional steps to increase awareness about medication to treat opioid use disorder 
among beneficiaries and individuals who help beneficiaries make health care 
decisions.  For example, through its National Training Program, CMS could create a 
training for its partners, not-for-profit professionals, and volunteers who work with 
older adults and people with disabilities.  The training could educate these individuals 
about Medicare coverage for opioid use disorder treatment including office-based 
treatment and opioid treatment programs, and how they can help beneficiaries find 
care.   
CMS should also more clearly state on its Medicare.gov website that beneficiaries can 
receive treatment for opioid use disorder at opioid treatment programs or in office-
based settings.  The website should provide a link for beneficiaries to find providers 
who offer treatment in office-based settings.  Currently, the website only provides a 
link that helps beneficiaries find treatment at opioid treatment programs.   
CMS should also target its outreach efforts to certain groups of beneficiaries who are 
less likely to receive medication to treat their opioid use disorder.  These should 
include beneficiaries in certain States and those who are older, Asian/Pacific Islander, 
Black, Hispanic, and female.    
Take steps to increase the number of providers and opioid treatment programs 
for Medicare beneficiaries with opioid use disorder 
CMS should take several steps to increase the number of providers who can treat 
beneficiaries for opioid use disorder in office-based settings.  CMS is in a unique 
position to conduct outreach to providers to encourage them to treat Medicare 
beneficiaries with opioid use disorder.  CMS has a number of mechanisms such as 
Medicare Learning Network alerts that can be used to communicate important 
information to providers.  CMS should use its outreach mechanisms to educate 
providers about Medicare coverage for opioid use disorder treatment.  The outreach 
could also provide information about which States or areas of the country have the 
greatest need for additional providers. 
CMS could also assess whether making changes to Medicare payment mechanisms 
could help increase the number of providers treating beneficiaries for opioid use 
disorder in office-based settings.  Specifically, it could assess whether its current 
payment mechanisms and reimbursement rates reflect the level of care necessary to 
treat beneficiaries for opioid use disorder, given the complex needs of this population.  
As part of this effort, CMS could determine why so few providers used the office-
based bundled payment codes when billing for opioid use disorder treatment in 2020.  
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Recommendations | 15  If necessary, based on the results of these assessments, CMS could adjust its payment 
mechanisms and reimbursement rates to better align them with the level of care 
required for treating beneficiaries with opioid use disorder in office-based settings.  
CMS could also consider developing an add-on code for the initiation of medication 
for the treatment of opioid use disorder in office-based settings similar to the new 
add-on code for the initiation of medication for the treatment of opioid use disorder 
in emergency department settings.57 
CMS should also continue its outreach efforts to increase the number of opioid 
treatment programs available to Medicare beneficiaries.  CMS has taken steps to 
increase the number of opioid treatment programs enrolled in Medicare, including 
working with SAMHSA to reach unenrolled opioid treatment programs.  CMS should 
continue these efforts.  In addition, CMS could provide information to States to help 
them determine whether the number of opioid treatment programs available to 
Medicare beneficiaries in certain States or areas is adequate.  CMS could also assess 
whether opioid treatment programs are facing any barriers to treating Medicare 
beneficiaries.  For example, CMS could determine whether the structure of the weekly 
bundled payments reflects the level of care required to treat a beneficiary.     
Assist SAMHSA by providing data about the number of Medicare beneficiaries 
receiving buprenorphine in office-based settings and the geographic areas 
where Medicare beneficiaries remain underserved  
Monitoring access to providers who are authorized to prescribe buprenorphine and 
determining which areas of the country need additional providers are important to 
ensuring access to treatment.  As the agency responsible for administering the 
Buprenorphine Waiver Program, SAMHSA is central to monitoring access to these 
providers.  However, SAMHSA lacks comprehensive data on the number of patients 
served under the program.   
To address this issue, SAMHSA recently concurred with an OIG recommendation to 
develop comprehensive methods and measures to assess access to buprenorphine 
prescribed or administered by waivered providers.58  To do this, SAMHSA is 
considering ways to increase its own capacity to collect and analyze existing 
administrative data, such as data from CMS, to monitor access to buprenorphine.   
To assist SAMHSA in its efforts, CMS should provide SAMHSA with data on the 
number of patients receiving buprenorphine and the geographic areas where patients 
with opioid use disorder remain underserved.  Because of its national scope and size, 
Medicare data may provide SAMHSA with important insights and help ensure access 
to treatment more widely. 
Take steps to increase the utilization of behavioral therapy among beneficiaries 
receiving medication to treat opioid use disorder  
Patients receiving medication to treat opioid use disorder may also benefit from 
behavioral therapy.  This therapy can increase patient engagement, modify patient 
behavior, and address co-occurring mental health disorders.  CMS should take steps 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Recommendations | 16  to increase the number of beneficiaries who receive behavioral therapy as a part of 
the treatment for opioid use disorder.  Taking into account shortages of behavioral 
health providers, CMS should conduct outreach to providers and beneficiaries that 
reinforces the benefits of behavioral therapy.  It could provide information to primary 
care providers about how they can help their Medicare patients connect with 
behavioral health providers by, for example, using the Medicare Find & Compare 
website to identify providers in their areas who treat opioid use disorder.59  
The outreach could also remind behavioral health care providers of the new bundle 
payment for opioid treatment. 
Create an action plan and take steps to address disparities in the treatment of 
opioid use disorder 
CMS should create an action plan and take steps to address disparities among 
Asian/Pacific Islander, Black, Hispanic, and other underserved communities in the 
treatment of opioid use disorder for Medicare beneficiaries.   
This standalone action plan should align with the overarching CMS Equity Plan 
developed by CMSs Office of Minority Health and use the CMS Health Equity 
Framework and the priorities within the plan as a foundation for establishing 
measurable, actionable goals to achieve health equity.  This action plan should 
identify ways to promote increased understanding and awareness of disparities in 
opioid use disorder, and develop promising approaches to reduce disparities in the 
treatment of opioid use disorder as well as steps to disseminate this information to 
providers and other stakeholders in order to reduce and eliminate disparities and 
achieve health equity.   
Furthermore, the actions outlined in this plan should include targeted outreach to 
providers who serve and beneficiaries who are members of these communities.  This 
outreach could ensure that there is more culturally sensitive and respectful care 
available for patients with opioid use disorder.  To conduct this outreach, it may be 
important to identify and collaborate with local leaders and groups within 
Asian/Pacific Islander, Black, and Hispanic communities where disparities are 
prevalent. 
CMS should use the data it is currently collecting on disparities and the data in this 
report to develop this plan.  It should also collaborate with the HHS Office of Minority 
Health and SAMHSA, as appropriate. 
Collect data on the use of telehealth in opioid treatment programs  
The use of telehealth to treat opioid use disorder is considered an important tool in 
ensuring access to care.  CMS currently does not monitor beneficiaries utilization of 
telehealth in opioid treatment programs or assess its impact on access to care.  This is 
because opioid treatment programs do not submit information about telehealth on 
Medicare claims.  CMS should require opioid treatment programs to indicate on 
Medicare claims when telehealth is used to provide care.  This information will allow 
CMS to monitor the use of telehealth at opioid treatment programs.   
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Recommendations | 17   
AGENCY COMMENTS AND OIG RESPONSE 
 
 
CMS concurred with four of our recommendations and did not explicitly indicate 
whether it concurred with the other two recommendations.   
CMS concurred with our recommendation to conduct additional outreach to 
beneficiaries to increase awareness about coverage for the treatment of opioid use 
disorder.  CMS noted that it has previously conducted extensive outreach to 
beneficiaries regarding Medicare coverage for the treatment of opioid use disorder 
and will continue to conduct outreach as appropriate.  CMS also stated that it has 
revised the Medicare & You Handbook and updated its website.  In addition, CMS 
stated that it is currently analyzing drivers of disparities in the use of medication to 
treat opioid use disorder and will target future outreach to specific populations as 
appropriate.   
CMS concurred with our recommendation to take steps to increase the number of 
providers and opioid treatment programs for Medicare beneficiaries with opioid use 
disorder.  CMS stated that it has previously conducted extensive outreach to providers 
and opioid treatment programs about opportunities to treat Medicare beneficiaries 
with opioid use disorder.  CMS also stated that it will continue to monitor payment 
mechanisms and rates for office-based treatment to assess their efficacy.   
CMS did not explicitly indicate whether it concurred with our recommendation to 
assist SAMHSA by providing data about the number of Medicare beneficiaries 
receiving buprenorphine in office-based settings and the geographic areas where 
Medicare beneficiaries remain underserved.  However, CMS stated that it regularly 
works with SAMHSA and will provide data when requested to do so.   
CMS also did not explicitly indicate whether it concurred with our recommendation to 
take steps to increase the utilization of behavioral therapy among beneficiaries 
receiving medication to treat opioid use disorder.  CMS noted that it has previously 
undertaken extensive outreach to beneficiaries to describe the benefits available to 
them for the treatment of opioid use disorder.  It also stated that it will continue 
outreach to both providers and beneficiaries to ensure awareness of all Medicare-
covered services and options.   
CMS concurred with our recommendation to create an action plan and take steps to 
address disparities in the treatment of opioid use disorder.  CMS stated that it has 
been working to identify and track drivers of disparities in the treatment of opioid use 
disorder.  CMS also stated that it will use its existing equity framework, as described in 
the Equity Plan for Medicare, to further analyze and develop existing opioid use 
disorder plans to address, and amend as needed, disparities in the treatment of 
opioid use disorder.  
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Agency Comments and OIG Response | 18  Lastly, CMS also concurred with our recommendation to collect data on the use of 
telehealth in opioid treatment programs.  CMS stated that it has finalized coding 
changes in the CY 2022 Physician Fee Schedule necessary to collect data to monitor 
the use of telehealth in opioid treatment programs.  These changes will include a 
requirement to use a service-level modifier for audio-only services billed using the 
counseling and therapy add-on code.  CMS also finalized that when two-way 
audio/video communication is used to furnish services billed under the counseling 
and therapy add-on code, opioid treatment programs will be required to append a 
modifier to the claim.  In addition to these steps, OIG encourages CMS to also collect 
information on counseling and therapy services delivered via telehealth included in 
the weekly bundled payments.   
For the full text of CMSs response, see Appendix D.  
 
 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Agency Comments and OIG Response | 19   
METHODOLOGY 
 
 
This data brief is based on the analysis of Medicare data from January 1, 2020, to 
December 31, 2020, including National Claims History File data, Part C Encounter 
Data, Part D prescription drug event (PDE) records, and the Medicare Enrollment 
Database.60  Part D sponsors submit a PDE record to CMS each time a drug is 
dispensed to a beneficiary enrolled in their plans.  Each record contains information 
about the drug and the beneficiary.  The National Claims History File contains claims 
data from Medicare Parts A and B.  Part C Encounter Data contain medical claims data 
for beneficiaries enrolled in Medicare Advantage plans.   
Identifying Beneficiaries with Opioid Use Disorder  
We determined the extent to which Medicare beneficiaries had diagnoses of opioid 
use disorder in 2020 using Medicare Parts A and B Claims Data and Part C Encounter 
Data.  We considered a beneficiary to have opioid use disorder if the beneficiary had a 
diagnosis code categorized as opioid abuse (F11.1) or opioid dependence (F11.2) 
on any claim during 2020, or if the beneficiary received service at an opioid treatment 
program in 2020.   
Analysis of MAT Drugs 
Using Medicare Part B Claims Data, Part C Encounter Data, and Part D PDE records, we 
determined the extent to which beneficiaries with opioid use disorder (as defined 
above) received MAT drugs through Medicare in 2020.  Throughout the report, we 
use the term beneficiaries who received medication to treat opioid use disorder to 
refer to these beneficiaries. 
First, we determined the number of beneficiaries with opioid use disorder who were 
prescribed or administered MAT drugs in office-based settings.  We considered MAT 
drugs to be prescribed or administered in office-based settings if they were 
prescribed by a health care provider and filled at a pharmacy (and covered under 
Part D), or if they were administered directly to a patient by a health care provider 
(and covered under Part B and Part C).  To identify these beneficiaries, we first used 
PDE records to identify the number of beneficiaries who filled prescriptions for MAT 
drugs at pharmacies in 2020.  We then used Medicare Part B Claims Data and Part C 
Encounter Data to identify the number of beneficiaries who were administered MAT 
drugs in a health care providers office.  We also determined the number of 
beneficiaries who received each type of MAT drug (i.e., buprenorphine or naltrexone) 
prescribed or administered in an office-based setting. 
Next, we determined the number of beneficiaries with opioid use disorder who 
received MAT drugs through opioid treatment programs.  To do this, we used 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Methodology | 20  Medicare Part B Claims Data and Part C Encounter Data to identify all beneficiaries for 
whom an opioid treatment program had billed at least one bundled payment code 
that included a MAT drug component.  We also determined the total number of 
beneficiaries who received each type of MAT drug (i.e., methadone, buprenorphine, or 
naltrexone).  Lastly, we determined how many beneficiaries received take-home doses 
of methadone and buprenorphine from opioid treatment programs.   
Analysis of Behavioral Therapy 
Using Medicare Part B Claims and Part C Encounter Data, we determined the extent to 
which beneficiaries with opioid use disorder who received MAT drugs also received 
behavioral therapy.  These services can be provided through individual providers in 
office-based settings or through opioid treatment programs.   
We first determined the extent to which beneficiaries who received MAT drugs in 
office-based settings also received behavioral therapy that was billed to Medicare.  To 
do this, we identified beneficiaries who received MAT drugs in office-based settings 
and received individual psychotherapy or group psychotherapy.  We also determined 
the number of these beneficiaries who received behavioral therapy through monthly 
office-based bundled payments.  In addition, we determined the extent to which any 
of these services were delivered via telehealth.  We considered a service to be 
delivered via telehealth when one of these codes had a modifier or Place of Service 
code indicating the service had been delivered via telehealth. 
We then determined the number of beneficiaries who received both MAT drugs and 
behavioral health services through opioid treatment programs.  We did this by 
identifying which beneficiaries received the opioid treatment programs bundled 
payment billing codes that include individual and group therapy components.  
Characteristics of Beneficiaries 
We also determined key characteristics of the beneficiaries who were less likely to 
receive MAT drugs.  To do this, we used the Medicare Enrollment Database file.  We 
first determined the percentage of beneficiaries in each State who received MAT 
drugs.  For each State, we determined the total number of opioid treatment programs 
enrolled in the Medicare program and the total number of health care providers who 
have a buprenorphine waiver from SAMHSA.61  We then calculated the number of 
each of these providers per 1,000 Medicare beneficiaries with opioid use disorder. 
We also determined each beneficiarys race and ethnicity, age, Part D low-income 
subsidy status, and sex.  In addition, we also determined the extent to which 
beneficiaries received MAT drugs in office-based settings and from opioid treatment 
programs by race and ethnicity.  Race and ethnicity information is based on data 
collected from the Social Security Administration and an algorithm developed by the 
Research Triangle Institute.  This algorithm attempts to improve the quality of the 
Social Security Administrations data by amending the race data for certain groups 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Methodology | 21  based on name and geography, as well as requests made by individuals for certain 
government materials to be provided in Spanish.62   
Limitations 
This study determines the extent to which beneficiaries received MAT drugs and 
therapy through Medicare.  Beneficiaries in this analysis may have received drugs or 
services through other payers, such as other insurance (e.g., plans covered by the 
Retiree Drug Subsidy), or self-pay.  We did not review the medical records or 
independently verify the accuracy of the Medicare claims data for this study.   
Standards 
We conducted this study in accordance with the Quality Standards for Inspection and 
Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.  
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Methodology | 22   
APPENDIX A 
 
Diagnostic Criteria of Opioid Use Disorder 
Exhibit A1: Diagnostic Criteria for Opioid Use Disorder* 
 
1.  Opioids are often taken in larger amounts or over longer periods than intended 
2.  There is a persistent desire or unsuccessful efforts to cut down or control opioid use 
3.  A great deal of time is spent in activities necessary to obtain an opioid, use an opioid, or 
recover from its effects 
4.  Craving or strong desire or urge to use opioids 
5.  Recurrent opioid use resulting in failure to fulfill major role obligations at work, school, or 
home 
6.  Continued opioid use despite persistent or recurrent social or interpersonal problems 
caused or exacerbated by effects of opioids 
7.  Important social, occupational, or recreational activities are given up or reduced because 
of opioid use 
8.  Recurrent opioid use in situations in which it is physically hazardous 
9.  Continued opioid use despite knowledge of a persistent or recurrent physical or 
psychological problem that is likely to have been caused or exacerbated by the 
substance 
10. Tolerance as defined by either: 
o  a need for markedly increased amounts of opioids to achieve intoxication or desired 
effect, or 
o  a markedly diminished effect with continued use of the same amount of opioids 
11. Withdrawal as manifested by either: 
o  the characteristic of opioid withdrawal syndrome, or  
o  opioids (or a closely related substance) are taken to relieve or avoid withdrawal 
symptoms 
 
 
* For a diagnosis of opioid use disorder, at least 2 of the 12 criteria should be observed within a 12-month period.  The presence 
of two or three symptoms is considered mild opioid use disorder.  The presence of four or five symptoms is considered moderate 
opioid use disorder.  Six or more symptoms is considered severe opioid use disorder.  There are some exceptions for considering 
tolerance and withdrawal as critical for opioid use disorder if the beneficiary is under appropriate medical supervision.  
Source: Diagnostic and Statistical Manual of Mental Disorders: DSM-5, 2013. 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Appendix A | 23   
APPENDIX B 
 
Medications Received by Medicare Beneficiaries to Treat Opioid 
Use Disorder 
 
Exhibit B1: Beneficiaries most commonly received buprenorphine to treat  
their opioid use disorder in 2020. 
 
   Beneficiaries  Percent    
Buprenorphine  125,321  75% 
 
Methadone  38,170  23% 
 
  Naltrexone  8,282  5% 
  Total  165,734*  100%** 
  * These data include the number of Medicare beneficiaries with opioid use disorder who received a MAT drug 
in office-based settings and opioid treatment programs.  A total of 4,005 beneficiaries received more than 
 
1 MAT drug. 
  ** The sum of this column does not equal 100 percent because some beneficiaries received more than 1 MAT 
  drug 
Source: OIG analysis of Medicare claims data, 2021. 
 
Exhibit B2: In office-based settings, beneficiaries most commonly received 
buprenorphine to treat their opioid use disorder.* 
MAT Drug  Total Number of Beneficiaries 
Buprenorphine   123,745** 
    Oral (tablets, sublingual film, buccal film)  123,583 
    Long-Acting Injectable  1,013 
Naltrexone  8,257*** 
    Tablets  6,888 
    Long-Acting Injectable  2,622 
Total  130,502**** 
* Methadone for MAT is not available in office-based settings. 
** A total of 851 received more than 1 form of buprenorphine.  
*** A total of 1,253 beneficiaries received more than 1 form of naltrexone.  
**** A total of 1,500 received both buprenorphine and naltrexone prescribed or administered in a providers office. 
Source: OIG analysis of Medicare claims data, 2021. 
 
 
 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Appendix B | 24  Exhibit B3: In opioid treatment programs, beneficiaries most commonly  
received methadone. 
MAT drug     Beneficiaries  
Methadone  38,170 
 
    Take-home doses    21,336 
Buprenorphine  2,164* 
 
    Oral Tablets  2,161 
 
          Take-home doses  1,253 
 
    Injection    6 
Injectable Naltrexone     26 
Total    39,602** 
* A total of three beneficiaries received more than one form of buprenorphine. 
** A total of 758 beneficiaries received more than 1 type of MAT drug. 
Source: OIG analysis of Medicare claims data, 2021. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Appendix B | 25   
APPENDIX C 
 
Percentage of Medicare Beneficiaries Who Received Medication 
to Treat Their Opioid Use Disorder in Each State 
Exhibit C1: Beneficiaries in Florida and Texas were the least likely to receive 
medication to treat their opioid use disorder in 2020. 
   Percent of beneficiaries with an opioid use disorder who received medication  
Prescribed or  Total Number  
Administered in an  Opioid Treatment  Who Received 
State  Office-Based Setting  Program  Total*  Medication 
Florida  5%  1%  5%  7,792 
Texas  6%  1%  6%  4,973 
Nevada  5%  2%  7%  988 
Kansas   6%  1%  7%  413 
Arizona  6%  3%  9%  2,735 
Louisiana  8%  1%  9%  2,358 
Oklahoma   8%  1%  10%  2,279 
Georgia  8%  2%  10%  2,908 
Idaho  10%  0%  10%  700 
Mississippi   9%  1%  10%  1,586 
Iowa  7%  5%  11%  474 
Nebraska  10%  1%  11%  280 
Colorado  9%  2%  11%  1,699 
California  7%  4%  11%  12,695 
Delaware  9%  3%  12%  770 
North Dakota  11%  1%  12%  110 
Arkansas   11%  1%  12%  1,063 
Missouri  12%  2%  14%  2,339 
Utah  13%  2%  14%  1,475 
South Dakota  14%  0%  14%  107 
Illinois  11%  3%  14%  2,971 
New Jersey  13%  4%  17%  4,089 
South Carolina  13%  4%  17%  2,201 
         
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Appendix C | 26   
Exhibit C1 (continued) 
   Percent of beneficiaries with an opioid use disorder who received medication  
Prescribed or  Total Number  
Administered in an  Opioid Treatment  Who Received 
State  Office-Based Setting  Program  Total*  Medication 
North Carolina  15%  3%  17%  6,416 
Minnesota  13%  5%  18%  2,049 
Wyoming  18%  1%  19%  142 
Indiana  16%  3%  19%  3,936 
New Mexico  16%  4%  19%  1,751 
Hawaii  13%  7%  20%  479 
Pennsylvania  17%  3%  20%  9,394 
Oregon  17%  4%  21%  3,112 
Washington  17%  4%  21%  5,033 
Virginia  16%  5%  21%  3,645 
Tennessee  18%  3%  21%  6,068 
Montana  18%  4%  22%  503 
Wisconsin  16%  6%  22%  2,432 
Michigan  17%  6%  23%  7,604 
Ohio  21%  4%  24%  7,847 
Alabama  21%  3%  25%  4,901 
Alaska  23%  3%  26%  329 
Kentucky  24%  3%  27%  5,926 
New York  18%  9%  27%  11,229 
District of 
24%  7%  30%  655 
Columbia 
Connecticut  18%  13%  30%  3,309 
Maryland  15%  17%  31%  5,711 
West Virginia  32%  5%  36%  2,554 
New Hampshire  34%  7%  40%  2,079 
Maine  37%  9%  45%  2,518 
Rhode Island  33%  14%  46%  1,760 
Massachusetts  35%  14%  48%  12,016 
Vermont  38%  21%  56%  1,305 
* The total percentages may be less than the sum of the office-based and opioid treatment program columns due to beneficiaries 
receiving MAT drugs in both settings. 
Source: OIG analysis of Medicare claims data, 2021. 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Appendix C | 27  APPENDIX D:  Agency Comments
DATE:  November 15, 2021 
TO:  Christi A. Grimm  
Principal Deputy Inspector General 
FROM:  Chiquita Brooks-LaSure 
Administrator 
SUBJECT:  Office of Inspector General (OIG) Draft Report: Many Medicare Beneficiaries 
Are Not Receiving Medication to Treat Their Opioid Use Disorder (OEI-02-20-
00390) 
The Centers for Medicare & Medicaid Services (CMS) appreciates the opportunity to review and 
comment on the Office of Inspector Generals (OIG) draft report. CMS is committed to ensuring 
that Medicare beneficiaries who have an opioid use disorder (OUD) have access to appropriate 
treatment, including Opioid Treatment Programs (OTPs) and office-based treatment. Ensuring 
access to these benefits and addressing equity concerns is an important part of combatting the 
nations opioid epidemic, and CMS has been actively engaged in the work necessary to meet 
these goals.  
Treatment through an OTP includes medication (such as methadone and buprenorphine), 
counseling, drug testing, and individual and group therapy. OTPs must be certified by the 
Substance Abuse and Mental Health Services Administration (SAMHSA) and enrolled in 
Medicare in order to be reimbursed for these services to Medicare beneficiaries. To implement 
Congress establishment of Medicare payment for OTPs under the SUPPORT Act, on January 1, 
2020, Medicare began paying Medicare-enrolled OTPs with a bundled payment to deliver OUD 
treatment services to Medicare beneficiaries. Medicare Advantage plans must also include the 
OTP benefit and can contract with OTP providers in their service area. CMS has also 
implemented office-based payment codes for treatment of OUD so that providers can offer care 
coordination, individual and group psychotherapy, and substance use counseling. These codes 
were expanded to be inclusive of all substance use disorders (SUDs), effective January 1, 2021. 
In addition, starting on January 1, 2021, Medicare Part B began covering hospital outpatient OTP 
services.  
To support the availability of opioid treatment services and encourage their use by eligible 
beneficiaries, in 2019, CMS began conducting outreach encouraging OTPs to enroll in Medicare, 
resulting in more than 1,250 OTPs enrolling by October 2021. This outreach comprised more 
than 20 separate communications to OTPs, multiple calls and listening sessions, the creation of 
two new web pages,1 and local engagement through the Medicare Administrative Contractors 
and CMS Regional Offices. Working with SAMHSA, CMS educated OTPs about becoming 
SAMHSA-certified; reached out to OTPs that were SAMHSA-certified but not yet enrolled in 
1 https://www.cms.gov/Center/Provider-Type/Opioid-Treatment-Program-Center and 
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/Opioid-Treatment-Program 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390    Appendix D | 28 Medicare through language in SAMHSAs OTP certification letter; and examined and addressed 
barriers to enrollment, such as lack of familiarity with the Medicare program and payment, as 
OUD treatment services furnished by OTPs were not previously a Medicare benefit. CMS also 
reached out to Medicare Advantage Organizations during this time to educate them on the 
benefit. CMS has made many enrollment, billing, and education resources for office-based 
providers and OTPs available on the OTP webpage on CMS.gov.  
Appropriate payment is an important part of ensuring provider participation and beneficiary 
access to care. CMS develops Medicare payment rates to meet statutory requirements including 
reflecting resource use for the care provided as appropriate. Prior to this audit, CMS has been 
monitoring the newly developed office-based bundled payment rates. This coding was new as of 
January 1, 2020, and was updated as of January 1, 2021 to include treatment for all substance use 
disorders, not just OUD. While OIG found that relatively few beneficiaries received behavioral 
therapy billed to Medicare through these office-based bundled payments, in addition to being 
new coding about which utilization data is still developing, the ongoing COVID-19 public health 
emergency may have also affected utilization. CMS is continuing to monitor this issue. In 
addition, to continue to facilitate access to the OTP benefit and improve our ability to collect 
data about use of telehealth, CMS finalized in the Calendar Year (CY) 2022 Physician Fee 
Schedule final rule a provision for OTPs to provide counseling and therapy services via audio-
only technology, such as telephone calls, after the conclusion of the Public Health Emergency 
when audio/video communication is not available to the patient. To assess availability and 
uptake of treatment options, CMS also finalized a requirement that OTPs track use of audio-only 
technology with a billing modifier. CMS also finalized that after the conclusion of the PHE for 
COVID-19, when two-way interactive audio/video communication technology is used to furnish 
additional counseling and therapy services billed under the counseling and therapy add-on code, 
OTPs will be required to append a modifier to the claim. The use of these modifiers will allow 
CMS to track utilization of these flexibilities in the claims data and to evaluate that data as we 
consider future refinements to the OTP benefit. CMS already monitors use of telehealth for OUD 
treatment in general, as OTPs are not the only source of treatment for OUDs. Beneficiaries can 
receive OUD treatment in other outpatient settings from physicians and certain non-physician 
practitioners, which can include evaluation and management services, psychotherapy services, or 
a bundle of office-based substance use disorder treatment services; and analysis of the claim can 
indicate whether that treatment for an OUD was furnished via telehealth. 
CMS takes seriously its role in ensuring beneficiaries understand the availability of these 
services, and as such, CMS has conducted outreach about the OTP benefit, including updating 
the Medicare & You Handbook to explain these benefits, as well as publishing blog posts and 
other information on Medicare.gov. CMS continues to update the Handbook, and has published 
changes in the 2022 Handbook that include information about coverage of office-based 
treatment. In addition, CMS updated the 2020 Medicare & You Handbook to highlight that 
behavioral health therapy is part of the OTP benefit and is covered both in-person and virtually, 
and expanded on this information in the 2021 Handbook. CMS also continues to promote 
behavioral health services to beneficiaries on the Medicare.gov website. CMS also initiated the 
Value in Opioid Use Disorder Treatment Demonstration Program in 2021, the goals of which 
include increasing access to opioid use disorder treatment services and improving physical and 
mental health outcomes for Medicare beneficiaries. The selected participants include providers 
located in three of the four states OIG cites in this report as having lower beneficiary use of 
medication for OUD treatment.2  
2 https://innovation.cms.gov/innovation-models/value-in-treatment-demonstration 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390                      Appendix D | 29 Because addressing disparities is also an important part of increasing access, CMS has 
established an Equity Plan for Medicare. This publication provides a framework for measurable, 
actionable goals to achieve health equity. It is currently being updated and will reflect CMS 
overall strategic plans as well as needs identified by stakeholders to expand an equity framework 
for the coming years. CMS has been working to identify and track drivers of disparities in the 
treatment of OUDs, and is following the framework established in the Equity Plan to analyze and 
develop a plan to address these disparities.  
Combatting the opioid epidemic is a priority for the agency, and we appreciate that the OIG 
recognizes that many ongoing efforts taken prior to the OIGs audit will be key in moving this 
effort forward.  
OIGs recommendations and CMS' responses are below. 
OIG Recommendation  
CMS should conduct additional outreach to beneficiaries to increase awareness about Medicare 
coverage for the treatment of opioid use disorder. 
CMS Response  
CMS concurs with this recommendation. Prior to this audit, CMS conducted extensive outreach 
to beneficiaries regarding Medicare coverage for the treatment of OUD, as detailed above, and 
will continue to conduct outreach as appropriate. Also prior to this audit, CMS finalized 
revisions and has now published the 2022 Medicare & You Handbook stating that beneficiaries 
can receive OUD treatment in office-based settings in addition to opioid treatment programs. The 
CMS website has also been updated to align messaging. To ensure that Medicare beneficiaries 
are connected with the provider who best fits their needs, CMS has detailed in the Handbook and 
website that beneficiaries should speak with their provider for information about where to go for 
these services. As stated above, CMS is currently analyzing drivers of disparities in use of 
medication to treat OUDs and will target future outreach to specific populations as appropriate. 
Regarding the availability of providers, we note that providers with a SAMHSA-issued 
buprenorphine waiver are limited in the number of patients they can treat, while some providers 
with waivers may not see the full panel of patients that a waiver would permit them to treat.   
OIG Recommendation  
CMS should take steps to increase the number of providers and opioid treatment programs for 
Medicare beneficiaries with opioid use disorder. 
CMS Response  
CMS concurs with this recommendation. Prior to this audit, CMS conducted extensive outreach 
to educate providers and Medicare-qualified SAMHSA-certified OTPs about opportunities to 
treat Medicare beneficiaries with OUDs. In order to provide treatment to Medicare beneficiaries, 
an OTP is required to have in effect a certification by SAMHSA and to be accredited by an 
accrediting body approved by SAMHSA. An office-based provider wishes to prescribe 
buprenorphine must also have a SAMHSA waiver, as described above. In addition, both office-
based providers and OTPs must also be enrolled in Medicare to treat Medicare beneficiaries. 
After the initial outreach campaign and follow-up starting in 2019, more than 70 percent of 
SAMSHA-certified OTPs became enrolled in Medicare. As stated above, CMS worked with 
SAMHSA to include language in their certification letter to OTPs describing how to enroll in 
Medicare, and this language has been included since 2019. Regarding current payment 
mechanisms for office-based treatment, CMS develops Medicare payment rates to meet statutory 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390                      Appendix D | 30 requirements including reflecting resource use for the care provided as appropriate. Prior to this 
audit, CMS has been monitoring these payment mechanisms and rates to assess their efficacy. 
This coding was new as of January 1, 2020, and was updated as of January 1, 2021 to include 
treatment for all substance use disorders, not just OUD. In addition to being new coding about 
which utilization data is still developing, the ongoing COVID-19 public health emergency may 
have also affected utilization. CMS is continuing to monitor this issue. 
OIG Recommendation  
CMS should assist SAMHSA by providing data about the number of Medicare beneficiaries 
receiving buprenorphine in office-based settings and the geographic areas where Medicare 
beneficiaries remain underserved. 
CMS Response  
CMS regularly works with, and will provide data when requested by, SAMHSA. 
OIG Recommendation  
CMS should take steps to increase the utilization of behavioral therapy among beneficiaries 
receiving medication to treat opioid use disorder. 
CMS Response  
Prior to this audit, as described above, CMS had undertaken extensive outreach to beneficiaries 
to describe benefits available to them for treatment of OUDs, including behavioral health 
therapy, and outreach to providers on how to enroll in Medicare and bill for these services. While 
treatment decisions and protocols are ultimately between the provider and beneficiary, CMS will 
continue outreach to both providers and beneficiaries to ensure awareness of all Medicare-
covered services and options. 
OIG Recommendation  
CMS should create an action plan and take steps to address disparities in the treatment of opioid 
use disorder. 
CMS Response  
CMS concurs with this recommendation. Prior to this audit, CMS has been working to identify 
and track drivers of disparities in the treatment of OUDs. CMS will use our existing equity 
framework, as described in the Equity Plan for Medicare, to further analyze and develop existing 
OUD plans to address, and amend as needed, disparities in the treatment of OUDs. 
OIG Recommendation  
CMS should collect data on the use of telehealth in opioid treatment programs. 
CMS Response  
CMS concurs with this recommendation. As stated above, prior to this audit, CMS proposed the 
claims coding changes that would be necessary to collect data to monitor use of telehealth in opioid 
treatment programs, and has now finalized these requirements as proposed in the CY 2022 
Physician Fee Schedule. Changes include a provision allowing OTPs to provide counseling and 
therapy services via audio-only technology, such as telephone calls, after the conclusion of the 
Public Health Emergency when audio/video communication is not available to the patient, and a 
requirement that OTPs use a service-level modifier for audio-only services billed using the 
counseling and therapy add-on code. CMS also finalized that after the conclusion of the PHE for 
COVID-19, when two-way interactive audio/video communication technology is used to furnish 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390                      Appendix D | 31 additional counseling and therapy services billed under the counseling and therapy add-on code, 
OTPs will be required to append a modifier to the claim. The use of these modifiers will allow 
CMS to track utilization of these flexibilities in the claims data and to evaluate that data as we 
consider future refinements to the OTP benefit.   
CMS thanks OIG for their efforts on this issue and looks forward to working with OIG on this and 
other issues in the future. 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390                      Appendix D | 32  
 ACKNOWLEDGMENTS AND CONTACT 
 
Acknowledgments 
Miriam Anderson served as the team leader for this study.  Others in the Office of 
Evaluation and Inspections who conducted the study include Margaret Himmelright 
and Jason Kwong.  Office of Evaluation and Inspections staff who provided support 
include Althea Hosein and Michael Novello.  
We would also like to acknowledge the contributions of other Office of Inspector 
General staff including Lauren McNulty.   
This report was prepared under the direction of Jodi Nudelman, Regional Inspector 
General for Evaluation and Inspections in the New York regional office, and 
Nancy Harrison and Meridith Seife, Deputy Regional Inspectors General. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Acknowledgments and Contact | 33  ENDNOTES 
 
 
1 These statistics are based on preliminary data.  See Centers for Disease Control and Prevention (CDC), Vital Statistics Rapid 
Release, Provisional Drug Overdose Death Counts, 12 Month-ending Provisional Number of Drug Overdose Deaths, August 1, 
2021.  Accessed at https://www.cdc.gov/nchs/nvss/vsrr/drug-overdose-data.htm on August 31, 2021. 
 
2 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2020.  Accessed at 
https://store.samhsa.gov/sites/default/files/SAMHSA_Digital_Download/PEP21-02-01-002.pdf on May 25, 2021. 
 
3 These medications are also sometimes called medications for opioid use disorder or MOUD. 
 
4  Buprenorphine is also separately indicated for pain.  Buprenorphine products indicated for pain are different than 
buprenorphine products indicated for the treatment of opioid use disorder. 
 
5 These waivers allowed certain practitioners to treat up to 100 patients with buprenorphine in the first year, although most 
qualified practitioners were limited to treating up to 30 patients in the first year.  See 21 U.S.C.  823(g)(2)(b)(III)(i).  In 
subsequent years, a practitioner can treat up to 275 patients.  See 42 CFR  8.610. 
 
6 Methadone can be prescribed for pain in other outpatient settings. 
 
7 Over time, these patients can receive up to one months worth of take-home doses.  See 42 CFR  8.12(h).  Also see SAMHSA, 
Federal Guidelines for Opioid Treatment Programs, January 2015.  Accessed at 
https://store.samhsa.gov/sites/default/files/d7/priv/pep15-fedguideotp.pdf on May 26, 2021.  SAMHSA has also increased the 
flexibility in dispensing take-home doses of methadone and other MAT drugs during the COVID-19 pandemic.  See SAMHSA, 
Opioid Treatment Program (OTP) Guidance, March 2020.  Accessed at https://www.samhsa.gov/sites/default/files/otp-
guidance-20200316.pdf on May 25, 2021. 
 
8 Prior to 2020, methadone for MAT was not covered by Part B because opioid treatment programs were not a recognized 
provider type in Medicare.  Beneficiaries enrolled in Medicare Advantage plans may have had opioid treatment program 
services covered prior to 2020 as a supplemental benefit.  CMS, Announcement of Calendar Year (CY) 2017 Medicare Advantage 
Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter, April 2016. 
 
9 SAMHSA, Naltrexone.  Accessed at https://www.samhsa.gov/medication-assisted-treatment/treatment/naltrexone on May 25, 
2021. 
 
10 42 C.F.R.  8.12(f). 
 
11 Each of these 1 million beneficiaries had a diagnosis of opioid use disorder on at least one Medicare claim in 2020 or 
received at least 1 service from an opioid treatment program in 2020.  For the purposes of this report, we refer to these 
beneficiaries as beneficiaries with opioid use disorder. 
 
12 For more information about assessing a patient for opioid use disorder, see CDC training document Module 5: Assessing and 
Addressing Opioid Use Disorder.  Accessed at https://www.cdc.gov/drugoverdose/training/oud/ on May 25, 2021. 
 
13 Diagnostic and Statistical Manual of Mental Disorders: DSM-5, 2013. 
 
14 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2020.  Continued treatment with MAT 
drugs for opioid use disorder is linked with better retention and outcomes, compared to treatment without MAT drugs. 
 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Endnotes | 34   
15 This number represents the proportion of beneficiaries who received MAT drugs through Medicare.  Additional beneficiaries 
may have received MAT drugs through other sources, such as by paying out-of-pocket. 
 
16 Food and Drug Administration, Information about Medication-Assisted Treatment (MAT).  Accessed at 
https://www.fda.gov/drugs/information-drug-class/information-about-medication-assisted-treatment-mat on May 25, 2021. 
 
17 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2020, p. ES-3.  Also see A. Sharma, et al., 
Update on Barriers to Pharmacotherapy for Opioid Use Disorders, Current Psychiatry Reports, 2017;19(6):35. 
 
18 National Institute of Drug Abuse, Words Matter  Preferred Language for Talking About Addiction.  Accessed at 
https://www.drugabuse.gov/drug-topics/addiction-science/words-matter-preferred-language-talking-about-addiction on  
June 14, 2021. 
 
19 CDC estimates that 4 in 10 adults in the United States delayed or avoided medical care because of concerns related to 
COVID-19.  See Mark E. Czeisler, Kristy Marynak, Kristie E.N. Clarke, et al., Delay or Avoidance of Medical Care Because of 
COVID-19-Related ConcernsUnited States, June 2020, Morbidity and Mortality Weekly Report,  69:12501257.  Accessed at 
https://www.cdc.gov/mmwr/volumes/69/wr/mm6936a4.htm#suggestedcitation on August 23, 2021.  To help ensure access to 
care, several rules related to the provision of MAT drugs were relaxed during the COVID-19 pandemic.  For more information, 
see Drug Enforcement Administration (DEA), COVID-19 Information Page.  Accessed at 
https://www.deadiversion.usdoj.gov/coronavirus.html on September 9, 2021. 
 
20 This analysis includes buprenorphine formulations indicated for the treatment of opioid use disorder.  It does not include 
formulations indicated for pain. 
 
21 To try to increase access during the COVID-19 pandemic, DEA allowed qualified providers to prescribe buprenorphine for 
MAT drugs via telephone without having first assessed patients in-person.  See DEA, Use of Telephone Evaluations to Initiate 
Buprenorphine Prescribing.  DEA also created exceptions for prescribing controlled substances across State lines during the 
COVID-19 Public Health Emergency.  See DEA, Exception to Separate Registration Requirements Across State Lines, March 2020.  
These documents are available on DEAs COVID-19 Information Page.  Accessed at 
https://www.deadiversion.usdoj.gov/coronavirus.html on September 22, 2021. 
 
22 OIG, Geographic Disparities Affect Access to Buprenorphine Services for Opioid Use Disorder, OEI-12-17-00240, January 2020. 
 
23 In total, 123,617 beneficiaries with opioid use disorder received buprenorphine for MAT covered by Part D in 2020.  This 
number includes drugs covered by Medicare Advantage prescription drug plans. 
 
24 In 2020, only 379 beneficiaries with opioid use disorder received buprenorphine for MAT administered in providers offices 
that was billed to Part B or Part C. 
 
25 A total of 8,146 beneficiaries with opioid use disorder received naltrexone that was covered by Part D. 
 
26 A total of 355 beneficiaries with opioid use disorder received naltrexone administered in a health care providers office that 
was covered by Part B or Part C. 
 
27 Section 2005 of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and 
Communities Act (SUPPORT Act, Pub. L. 115-271, enacted October 24, 2018) established a new benefit for opioid use disorder 
treatment services furnished by an opioid treatment program beginning on or after January 1, 2020.  See 84 F.R. 62649.  An 
opioid treatment program must be enrolled in Medicare to receive reimbursement for services provided to Medicare 
beneficiaries. 
 
28 There were approximately 1,170 opioid treatment programs enrolled in Medicare in the United States and its territories in 
2020, but distribution of programs is not even across the States.  Notably, State laws related to opioid treatment programs 
differ.  For instance, some States have laws and regulations related to where opioid treatment programs can be located.  See 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Endnotes | 35   
J.R. Jackson, et al., Characterizing Variability in State-Level Regulations Governing Opioid Treatment Programs, Journal of 
Substance Abuse Treatment 115, 2020. 
 
29 Under certain circumstances, patients are permitted to take home doses of both buprenorphine and methadone, thus 
alleviating the need to travel each day.  See 42 CFR  8.12(h).  Also see SAMHSA, Federal Guidelines for Opioid Treatment 
Programs, January 2015.  Accessed at https://store.samhsa.gov/sites/default/files/d7/priv/pep15-fedguideotp.pdf on May 26, 
2021.  SAMHSA has also increased the flexibility in dispensing take-home doses of methadone and other MAT drugs during 
the COVID-19 pandemic.  See SAMHSA, Opioid Treatment Program (OTP) Guidance, March 2020.  Accessed at 
https://www.samhsa.gov/sites/default/files/otp-guidance-20200316.pdf on May 25, 2021. 
 
30 B. Andraka-Christou, Addressing Racial and Ethnic Disparities in the Use of Medications for Opioid Use Disorder, Health 
Affairs, June 2021, Vol. 6 No. 40. 
 
31 In 2020, 21,336 beneficiaries received take-home doses of methadone. 
 
32 Beneficiaries who receive buprenorphine tablets are able to receive take-home doses.  A total of 1,253 beneficiaries did so. 
 
33 ASPE, Psychosocial Supports in Medication-Assisted Treatment: Recent Evidence and Current Practice, 2019.  Accessed at 
https://aspe.hhs.gov/system/files/pdf/262031/MATPsychLR.pdf on May 26, 2021. 
 
34 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2020. 
 
35 A total of 5,296 beneficiaries with opioid use disorder received both individual and group psychotherapy. 
 
36 Instead, buprenorphine waivered providers must be able to provide beneficiaries with referrals to case-management 
services, which can include behavioral health services.  Since April 2021, providers who plan to treat up to 30 patients have 
been exempt from this requirement.  See 86 F.R. 22439. 
 
37 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2020. 
 
38 In an analysis of beneficiaries enrolled in Medicare Fee-For-Service, CMS found that about 56 percent of the beneficiaries 
with an opioid use disorder also had anxiety and about 52 percent had depressive disorder.  See CMS, Medicare Fee-For-Service 
Beneficiaries with Opioid Use Disorder in 2018: Disparities in Prevalence by Beneficiary Characteristics, December 2020.  
Accessed at https://www.cms.gov/files/document/oud-disparities-prevalence-2018-medicare-ffs-dh-002.pdf on September 2, 
2021. 
 
39 Section 2001 of the SUPPORT Act removed geographic originating site requirements for telehealth for the treatment of 
substance use disorders and co-occurring mental health disorders effective July 1, 2019.  It also made an individuals home a 
permissible originating site.  P.L. No. 115-271  2001. 
 
40 CMS, COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, May 2021.  Accessed at 
https://www.cms.gov/files/document/covid-19-emergency-declaration-waivers.pdf on May 25, 2021. 
 
41 84 F.R. 62674.  Beginning in 2021, these bundled payments were expanded to include the treatment of all substance use 
disorders.  See 85 F.R. 84643. 
 
42 42 C.F.R.  8.12(f). 
 
43 CMS requires opioid treatment programs to use a Place of Service code specific to opioid treatment programs (i.e., Place of 
Service code 58) instead of denoting a telehealth-specific Place of Service code (i.e., Place of Service code 02) on claims 
submitted to Medicare.  CMS has continued to instruct opioid treatment programs to use this opioid treatment program-
specific Place of Service code during the COVID-19 Public Health Emergency.  See CMS, Billing & Payment, COVID-19: CMS 
Allowing Audio-Only Calls for OTP Therapy, Counseling, and Periodic Assessments, January 2021. 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Endnotes | 36   
 
44 During the COVID-19 Public Health Emergency, CMS instructed other health care providers delivering services via telehealth 
to use a modifier (modifier 95) specific to telehealth on their claims.  CMS, COVID-19 Frequently Asked Questions (FAQs) on 
Medicare Fee-for-Service (FFS) Billing, March 2020.  Accessed at https://www.cms.gov/files/document/03092020-covid-19-faqs-
508.pdf on May 25, 2021.  Additional modifiers that indicate telehealth include GT and GQ. 
 
45 Kansas had slightly more providers with 64 per 1,000 Medicare beneficiaries with opioid use disorder, which was the 12th 
lowest rate in the country. 
 
46 OIG, Geographic Disparities Affect Access to Buprenorphine Services for Opioid Use Disorder, OEI-12-17-00240, January 2020.  
Also see OIG, Behavioral HealthMedication-Assisted Treatment Viewer. 
 
47 Florida, Texas, Nebraska, and Idaho each had less than 0.8 opioid treatment programs per 1,000 Medicare beneficiaries with 
opioid use disorder.  These States were in the lowest one-quarter of States in terms of the number of programs per beneficiary.  
No opioid treatment programs enrolled in the Medicare program are in either Wyoming or South Dakota.  North Dakota had a 
higher number of opioid treatments programs, with 3.3 per 1,000 Medicare beneficiaries with opioid use disorder.  These 
counts include Medicare-enrolled opioid treatment programs. 
 
48 Note that Medicare data combine race and ethnicity and allow for only one response.  Furthermore, we did not include 
information on American Indian/Alaska Native beneficiaries because of limitation.  This analysis uses the race and ethnicity 
information from Medicares enrollment database, which is based on data collected from the Social Security Administration 
and an algorithm.  Although this information is currently the best available for the entire Medicare beneficiary population, 
comparisons to self-reported data (available in certain, limited circumstances) show that race and ethnicity is still misclassified 
for some beneficiaries.  In particular, Medicare beneficiaries with a race and ethnicity of American Indian/Alaska Native, 
Asian/Pacific Islander, or Hispanic are more likely to be misclassified.  For a fuller discussion about the data, please see our 
forthcoming report Medicare Data on Race and Ethnicity, OEI-02-21-00100. 
 
49 B. Andraka-Christou, Addressing Racial and Ethnic Disparities in the Use of Medications for Opioid Use Disorder, Health 
Affairs, June 2021, Vol. 6 No. 40. 
 
50 Over time, patients can receive up to one months worth of take-home doses. 
 
51 SAMHSA, The Opioid Crisis and The Black/African American Population: An Urgent Issue, April 2020.  Accessed at 
https://store.samhsa.gov/sites/default/files/SAMHSA_Digital_Download/PEP20-05-02-001_508%20Final.pdf on June 21, 2021.  
Also see SAMHSA, The Opioid Crisis and The Hispanic/Latino Population: An Urgent Issue, July 2020.  Accessed at 
https://store.samhsa.gov/sites/default/files/SAMHSA_Digital_Download/PEP20-05-02-002_0.pdf on June 21, 2021. 
 
52 42 C.F.R.  423.315(d). 
 
53 84 F.R. 62665; 42 C.F.R.  410.67(e). 
 
54 The new Practice Guidelines for Prescribing Buprenorphine exempt providers who plan to treat up to 30 patients from some 
of the requirements related to training, counseling, and other services.  See 86 F.R. 22439.  Also, in 2021 CMSs Center for 
Medicare and Medicaid Innovation implemented a demonstration program, Value in Opioid Use Disorder Treatment that is 
intended to increase access, improve outcomes, and reduce Medicare expenditure.  CMS, Value in Opioid Use Disorder 
Treatment Demonstration.  Accessed at https://innovation.cms.gov/innovation-models/value-in-treatment-demonstration on 
May 13, 2021. 
 
55 Section 2002 of the SUPPORT Act required that beginning January 1, 2020, annual wellness visits and initial preventative 
physical examinations include screening of potential substance use disordersincluding opioid use disorderand a review of 
any current prescriptions for opioids.  CMS added this change to the Physician Fee Schedule for 2021.  See 85 F.R. 85025. 
 
56 See 85 F.R. 84644. 
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Endnotes | 37   
 
57 Ibid. 
 
58 OIG, SAMHSA Is Missing Opportunities To Better Monitor Access to Medication-Assisted Treatment Through the Buprenorphine 
Waiver Program, OEI-BL-20-00260,  June 2021. 
 
59 The Medicare Find & Compare website is available at https://www.medicare.gov/care-compare/.  
 
60 We conducted this analysis based on Medicare data available as of July 21, 2021. 
 
61 To identify opioid treatment programs, we used CMSs Provider Enrollment, Chain, and Ownership System and CMSs Opioid 
Treatment Program Providers dataset which is available at https://data.cms.gov/provider-characteristics/medicare-provider-
supplier-enrollment/opioid-treatment-program-providers.  We identified providers who had SAMHSA waivers to prescribe 
buprenorphine in an office-based setting using DEA data. 
 
62 Although this information is currently the best available for the entire Medicare beneficiary population, comparisons to self-
reported data (available in certain, limited circumstances) show that race and ethnicity are still misclassified for some 
beneficiaries.    
 
Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder 
OEI-02-20-00390  Endnotes | 38