Georgia Medicare OTP Coverage

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By Brevy Care Team · Last verified May 13, 2026

Before January 1, 2020, Medicare did not cover Opioid Treatment Program services. Medicare beneficiaries with opioid use disorder could not access methadone treatment under their Medicare benefits, leaving a coverage gap that contributed to overdose deaths among older Americans. Section 2005 of the SUPPORT for Patients and Communities Act of 2018 (Public Law 115-271) closed that gap by adding Section 1861(jjj) to the Social Security Act and authorizing Medicare coverage of OTP services for the treatment of OUD. CMS implemented the benefit through the CY 2020 Physician Fee Schedule Final Rule and 42 CFR 410.67. The benefit pays OTPs a weekly bundled payment covering medication-assisted treatment, individual and group counseling, drug testing, and intake services, with HCPCS bundle codes G2067 through G2080 representing different medication and episode types. This guide explains the statutory framework, the SAMHSA 42 CFR Part 8 certification requirement, the DEA registration requirement, the methadone, buprenorphine, and naltrexone medication modalities, the MAT Act 2022 X-waiver elimination, the 42 CFR Part 2 substance use disorder records confidentiality framework, and how Georgia beneficiaries access OTP services. OTP services carry zero beneficiary cost-sharing, making them one of only a handful of Part B benefits with no coinsurance or deductible. :::

::: callout Key takeaways

• Section 1861(jjj) of the Social Security Act, added by SUPPORT Act 2018 Section 2005, established Medicare coverage of OTP services effective January 1, 2020. Before that date, methadone treatment for OUD was not covered by Medicare.
• 42 CFR 410.67 implements the benefit, requiring SAMHSA certification under 42 CFR Part 8, DEA registration, accreditation by an approved accreditor (CARF, Joint Commission, or COA), and Medicare enrollment.
• The OTP benefit uses a WEEKLY BUNDLED PAYMENT covering the MAT medication, individual and group counseling, drug testing, intake activities, and periodic assessments. HCPCS G2067 through G2080 represent the bundle codes.
• OTP services have ZERO beneficiary cost-sharing. The Part B deductible does not apply and there is no 20% coinsurance. The beneficiary pays $0 out of pocket.
• Three FDA-approved MAT medications: methadone (Schedule II, dispensed only at OTPs), buprenorphine (Schedule III, dispensed at OTPs or community pharmacies), and naltrexone (not controlled, agonist antagonist).
• The Mainstreaming Addiction Treatment (MAT) Act of 2022, enacted in CAA 2023, eliminated the DATA 2000 X-waiver effective January 12, 2023, allowing any DEA-registered practitioner to prescribe buprenorphine for OUD.
• 42 CFR Part 2 provides heightened confidentiality protection for SUD records. The SAMHSA Final Rule of February 2024 aligned 42 CFR Part 2 more closely with HIPAA while preserving protection against use in criminal proceedings.
• Georgia has approximately 55-60 SAMHSA-certified OTPs concentrated in metro Atlanta, Augusta, Savannah, Macon, Columbus, Albany, and Valdosta, with mobile medication units serving some rural areas. Approximately 75,000 Medicare beneficiaries received OTP services nationally in 2024. :::

A benefit that did not exist five years ago: how Medicare started covering opioid use disorder treatment

For most of Medicare's history, beneficiaries with opioid use disorder were in an unusual position. Medicare covered hospital detoxification, mental health counseling, and certain medications for OUD prescribed in physician offices. But Medicare did not cover services provided at Opioid Treatment Programs (OTPs), the SAMHSA-certified facilities that are the only authorized sites for dispensing methadone for OUD treatment. A 70-year-old Medicare beneficiary in Atlanta who developed OUD after a back surgery could not use Medicare to pay for methadone maintenance. The cost of self-pay methadone treatment, typically $500-700 per month, was beyond reach for most Medicare beneficiaries on fixed incomes. The result was predictable: beneficiaries went without treatment, relapsed, and died.

The coverage gap had nothing to do with clinical effectiveness. Methadone has been FDA-approved for OUD treatment since 1972 and is among the most studied medical interventions in modern medicine, with Cochrane reviews and meta-analyses consistently showing 60-70% reductions in opioid use and 50-70% reductions in overdose deaths. The coverage gap was a historical artifact: when Medicare was created in 1965 and modified in subsequent decades, OUD treatment was viewed primarily as a substance abuse service rather than a medical service, and methadone clinics were funded through state and federal grant programs outside Medicare.

The opioid overdose crisis forced a reckoning. By 2018, opioid overdose deaths exceeded 70,000 per year nationally and were rising among adults 65 and older. Congress acted with rare bipartisan unity, passing the SUPPORT for Patients and Communities Act of 2018 (Public Law 115-271) and Section 2005 within it. Section 2005 added Section 1861(jjj) to the Social Security Act, establishing the OTP benefit effective January 1, 2020.

CMS implemented the benefit through the CY 2020 Physician Fee Schedule Final Rule (84 FR 62568, November 15, 2019), creating 42 CFR 410.67 and establishing a unique weekly bundled payment structure. The bundle includes all the services typically provided at an OTP: the MAT medication, individual and group counseling, drug testing, intake activities, and periodic assessments. And critically, CMS established the benefit with ZERO beneficiary cost-sharing. No Part B deductible. No 20% coinsurance. The OTP receives the bundled payment from Medicare, and the beneficiary pays nothing out of pocket.

This guide explains how the OTP benefit works in detail: the statutory framework, the implementing regulations, the SAMHSA certification process, the DEA registration requirements, the medication modalities (methadone, buprenorphine, naltrexone), the MAT Act 2022 elimination of the DATA 2000 X-waiver, the 42 CFR Part 2 confidentiality framework, and how Georgia beneficiaries access OTP services.

The SUPPORT for Patients and Communities Act of 2018: Section 2005 establishes Medicare OTP coverage

Statutory framework

The SUPPORT Act of 2018 was signed by President Trump on October 24, 2018, after passing the Senate 98-1 and the House 393-8 (one of the most bipartisan substantive bills of the era). The Act contained more than 70 provisions addressing the opioid crisis through prevention, treatment, recovery, and law enforcement. Section 2005 specifically addressed the Medicare OTP coverage gap.

Section 2005 amended Section 1861 of the Social Security Act to add a new subsection (jjj) defining "opioid use disorder treatment services":

"(jjj) OPIOID USE DISORDER TREATMENT SERVICES; OPIOID TREATMENT PROGRAM.: (1) OPIOID USE DISORDER TREATMENT SERVICES.:The term 'opioid use disorder treatment services' means items and services that are furnished by an opioid treatment program for the treatment of opioid use disorder, including: (A) opioid agonist and antagonist treatment medications (including oral, injected, or implanted versions) that are approved by the Food and Drug Administration under section 505 of the Federal Food, Drug, and Cosmetic Act for use in the treatment of opioid use disorder; (B) dispensing and administration of such medications, if applicable; (C) substance use counseling by a professional to the extent authorized under State law to furnish such services; (D) individual and group therapy with a physician or psychologist (or other mental health professional to the extent authorized under State law); (E) toxicology testing, and (F) other items and services that the Secretary determines are appropriate (but in no event to include meals or transportation)."

The definition is comprehensive and intentionally broad. It includes all three FDA-approved MAT modalities, all counseling required for evidence-based treatment, and all routine drug testing.

Section 2005 also defined "opioid treatment program" for Medicare purposes as an entity that is:

• Enrolled with Medicare
• Certified by SAMHSA under 42 CFR Part 8
• Accredited by an accreditation body approved by SAMHSA

Effective date: January 1, 2020.

CY 2020 PFS Final Rule implementation

CMS implemented Section 1861(jjj) through 42 CFR 410.67, finalized in the CY 2020 Physician Fee Schedule Final Rule. The implementation:

1. Established the weekly bundled payment methodology
2. Created HCPCS bundle codes G2067 through G2080
3. Set the rates for the drug component and non-drug component
4. Set the geographic adjustment methodology
5. Established the zero-cost-sharing rule
6. Set the OTP enrollment process

The CY 2020 PFS Final Rule (84 FR 62568) is the foundational implementing document for Medicare OTP coverage. Subsequent annual PFS rules have updated the payment rates and bundle structures.

42 CFR 410.67: the conditions of coverage in detail

42 CFR 410.67(a): scope of services

42 CFR 410.67(a) defines the scope of OTP services. The bundle includes:

The bundle does NOT include:

• Services provided outside the OTP (covered separately under other benefit categories)
• Inpatient detoxification (covered under Part A)
• Mental health services for non-SUD conditions (covered under Part B mental health)
• Office-based buprenorphine prescribed by non-OTP practitioners (covered under standard Part B physician services and Part D for the medication)

42 CFR 410.67(b): coverage conditions

Medicare pays for OTP services when:

1. The OTP is enrolled in Medicare
2. The OTP is SAMHSA-certified under 42 CFR Part 8
3. The OTP is accredited by an accreditation body approved by SAMHSA
4. The OTP is DEA-registered if dispensing opioid agonists
5. The beneficiary has a documented diagnosis of OUD (DSM-5 or ICD-10)
6. The services are medically necessary

42 CFR 410.67(c): OTP enrollment

OTPs must complete Medicare enrollment through CMS-855B. Enrollment requires demonstration of:

• Current SAMHSA certification
• Current accreditation
• Current DEA registration (Schedule II for methadone, Schedule III for buprenorphine)
• State licensure
• Compliance with quality and safety standards

As of 2026, approximately 1,800 OTPs are enrolled with Medicare nationally. Georgia has approximately 55-60 SAMHSA-certified OTPs, with most enrolled with Medicare.

42 CFR 410.67(f): zero cost-sharing

42 CFR 410.67(f) establishes that OTP services have NO Medicare beneficiary cost-sharing:

• The Part B deductible does NOT apply
• The 20% coinsurance does NOT apply
• The beneficiary pays $0 for the OTP weekly bundle

This is one of only a handful of Part B benefits with zero cost-sharing. Others include the Annual Wellness Visit (Section 1861(hhh)), USPSTF Grade A and B preventive services (Section 1861(ddd)), the Medicare Diabetes Prevention Program (42 CFR 410.79), and certain COVID-19 services. CMS rationale (84 FR 62588): cost-sharing barriers contribute to treatment discontinuation and overdose risk in vulnerable populations, and the public health benefit of full-utilization OTP access outweighs the modest cost-shifting that beneficiary coinsurance would produce.

HCPCS G2067 through G2080: the weekly bundled payment structure

Bundle code overview

CMS established HCPCS codes G2067 through G2080 to represent the OTP weekly bundles. The codes are categorized by:

1. Type of medication (methadone, buprenorphine, naltrexone)
2. Drug delivery form (oral, sublingual, injectable, implant)
3. Episode type (initial intake vs. continuing maintenance)
4. Add-on services (intake, take-home doses, additional counseling)

Methadone codes

Buprenorphine codes

Naltrexone codes

Other codes

Payment amounts (approximate 2026)

CMS publishes annual updated payment amounts in the PFS Final Rule. Approximate 2026 Georgia payment amounts (subject to geographic adjustment via GPCI):

The payment is divided into a drug component (reflecting average wholesale price of the medication) and a non-drug component (counseling, drug testing, overhead). Geographic adjustment applies only to the non-drug component.

Atlanta versus Rest of Georgia GPCI

Georgia has two PFS localities:

The Atlanta locality non-drug component is slightly higher than Rest of Georgia. The difference is modest (1-3% on the total bundle).

SAMHSA certification: 42 CFR Part 8

Federal certification framework

OTPs must be certified by the Substance Abuse and Mental Health Services Administration (SAMHSA) under 42 CFR Part 8, which implements 21 USC 823(g) (the federal Controlled Substances Act). Certification establishes that the OTP meets federal standards for:

• Medical, counseling, vocational, educational, and other assessment and treatment services
• Adequate medical supervision by qualified medical director
• Patient admission criteria
• Diversion control of opioid agonist medications
• Adequate facility and equipment
• Quality assurance and improvement program
• Patient confidentiality

Accreditation requirement

42 CFR Part 8 requires OTPs to be accredited by a SAMHSA-approved accreditation body. Currently approved accreditors:

• Commission on Accreditation of Rehabilitation Facilities (CARF International)
• The Joint Commission (TJC)
• Council on Accreditation (COA)
• National Commission on Correctional Health Care (NCCHC, for correctional OTPs)
• State authorities of certain states (MA, ME, OK, VA, WA)

Accreditation surveys are conducted every three years and evaluate clinical operations, governance, quality improvement, outcomes, and patient experience.

Certification renewal

OTP certification must be renewed every three years (sponsoring agency level) and annually (program registration). Renewal requires:

• Current accreditation
• Continued compliance with 42 CFR Part 8 standards
• Quality assurance data submission
• Diversion control plan implementation

SAMHSA Final Rule of February 2024

The SAMHSA Final Rule published February 8, 2024 (89 FR 12472) modernized 42 CFR Part 8 standards, including:

• Permanent authorization of methadone initiation via audio-video telehealth
• Permanent authorization of buprenorphine initiation via audio-video or audio-only telehealth (for OTPs)
• Expanded take-home methadone flexibility (14 days for 30-day stable patients, 28 days for 60-day stable patients) as a permanent baseline
• Reduced minimum required clinic counseling hours
• Patient-centered care emphasis (replacing prescriptive minimums with individualized care plans)
• Mobile medication unit (MMU) rule enhancements

Compliance deadline: October 2, 2024 (with continued implementation through 2026).

DEA registration: 21 CFR Part 1301

OTPs that dispense methadone (Schedule II controlled substance under the Controlled Substances Act) or buprenorphine (Schedule III) must register with the Drug Enforcement Administration under 21 CFR Part 1301.

DEA registration:

• Permits the OTP to receive, store, dispense controlled substances
• Specifies the OTP's Schedule II and III narcotic treatment program authority
• Requires compliance with DEA recordkeeping (inventory logs, dispensing records)
• Subjects the OTP to DEA inspections (announced and unannounced)

DEA registration is renewed every three years. The OTP must report any diversion (theft, loss, fraudulent prescriptions) to DEA. Diversion of methadone is a federal felony.

DEA contact: 1-800-882-9539.

The three MAT medications

Methadone

Methadone is a long-acting full opioid agonist (mu-opioid receptor). FDA-approved for OUD since 1972. Properties:

• Schedule II controlled substance
• Dispensed ONLY at SAMHSA-certified OTPs for OUD (federal law, 21 CFR 1306.07)
• Cannot be prescribed by a physician's office or filled at a community pharmacy for the OUD indication
• Typical maintenance dose: 60-120 mg per day
• Long half-life (24-36 hours) supports once-daily dosing
• Strong evidence base: reduces opioid use 60-70%, overdose death 50-70%

Buprenorphine

Buprenorphine is a partial opioid agonist FDA-approved for OUD since 2002. Multiple formulations:

Schedule III controlled substance. Can be prescribed by any DEA-registered practitioner (since MAT Act 2022 eliminated X-waiver January 12, 2023). Can be filled at community pharmacies. Lower overdose risk than methadone due to ceiling effect on respiratory depression.

Naltrexone

Naltrexone is a full opioid antagonist FDA-approved for OUD relapse prevention since 1984 (oral) and 2010 (extended-release injectable):

Not a controlled substance. Can be prescribed by any practitioner. Patient must complete opioid detoxification (7-10 days opioid-free) before starting naltrexone to avoid precipitated withdrawal. Lower retention rates than methadone or buprenorphine but useful for highly motivated patients who cannot use agonists (e.g., patients who must avoid all opioids for legal or professional reasons).

The Mainstreaming Addiction Treatment (MAT) Act of 2022: eliminating the X-waiver

The original DATA 2000 X-waiver

The Drug Addiction Treatment Act of 2000 (Public Law 106-310, "DATA 2000") created a path for office-based buprenorphine treatment as an alternative to OTP-based methadone. However, DATA 2000 required physicians to obtain a special DEA registration ("X-waiver") to prescribe buprenorphine for OUD. Requirements:

• 8-hour training course for physicians (24 hours for NPs and PAs)
• Special DEA application and registration ("X" prefix on DEA number)
• Patient panel limits (initially 30, expanded over time to 100, then 275)
• Recordkeeping obligations

The X-waiver was widely criticized as a major access barrier. Only approximately 7% of U.S. physicians obtained the waiver, leaving most communities without buprenorphine prescribers and forcing patients to travel long distances or remain untreated.

MAT Act 2022 eliminates the X-waiver

The Mainstreaming Addiction Treatment (MAT) Act of 2022, enacted as part of the Consolidated Appropriations Act of 2023 (Public Law 117-328) signed December 29, 2022, eliminated the DATA 2000 X-waiver effective January 12, 2023.

Effective January 12, 2023:

• Any DEA-registered practitioner can prescribe buprenorphine for OUD
• No special X-waiver required
• No 8-hour training required (specifically for X-waiver purposes)
• No patient panel limits
• Standard DEA registration alone is sufficient

This change dramatically expanded buprenorphine access. Primary care physicians, internists, psychiatrists, emergency physicians, hospitalists, and many other practitioners can now prescribe buprenorphine without specialized DEA registration. The result has been measurable increases in buprenorphine prescribing in primary care settings, particularly in rural areas previously underserved.

Mandatory SUD training under SUPPORT Act 2018

Separate from the X-waiver elimination, the SUPPORT Act of 2018 Section 1263 established a one-time 8-hour SUD training requirement for ALL DEA-registered practitioners (not just buprenorphine prescribers). This training:

• Covers safe prescribing of controlled substances
• Covers identification and treatment of SUD
• Can be completed through various approved providers (AMA, AAFP, ACEP, ACP, AAPA, AANP, others)
• Is mandatory for any DEA registration or renewal occurring after June 27, 2023
• Is one-time, not recurring

This training substantially raised the SUD-knowledge floor across the prescriber workforce.

42 CFR Part 2: SUD records confidentiality

Background and protection

42 CFR Part 2 provides heightened confidentiality protection for substance use disorder treatment records, more stringent than HIPAA. The regulation dates to the Drug Abuse Office and Treatment Act of 1972 and was substantially revised in 2017, 2020, and 2024.

Core protection: SUD records cannot be used in criminal proceedings against the patient without:

• The patient's written consent specifically authorizing such use, OR
• A court order specifically authorizing the disclosure based on good cause

This protection is stronger than HIPAA. Under HIPAA alone, SUD records could be released to law enforcement with a subpoena. Under 42 CFR Part 2, a subpoena is not sufficient; a court order is required.

SAMHSA Final Rule of February 2024

The SAMHSA Final Rule of February 2024 (89 FR 12472) substantially revised 42 CFR Part 2 to align more closely with HIPAA while preserving the criminal-proceedings protection. Key changes:

1. Single consent for treatment, payment, healthcare operations: A single written consent permits future uses and disclosures for these purposes, consistent with HIPAA
2. Care coordination: SUD records may be shared for care coordination without separate authorization in many circumstances
3. Patient safety exception: Disclosure permitted when necessary to prevent serious imminent harm
4. Civil and administrative proceedings: Patient consent or court order still required
5. Criminal proceedings: Heightened protection retained
6. Compliance deadline: February 16, 2026

The revised rule reduces administrative burden on providers while preserving core legal protection.

Practical applications

Common 42 CFR Part 2 scenarios:

• Sharing MAT status with hospital: OTP can share with patient's consent (under modernized rule, single consent covers care coordination)
• Reporting to Medicare for claims: Permitted under treatment-payment-operations exception
• Responding to subpoena: Subpoena alone insufficient; court order required for disclosure in legal proceedings
• Sharing with PDMP: Permitted under specific exception for PDMP queries
• Reporting overdose to family: Generally requires consent unless emergency exception applies

Telehealth and the SAMHSA Final Rule

The SAMHSA Final Rule of February 2024 made permanent many pandemic telehealth flexibilities:

The DEA Final Rule of October 2024 (89 FR 80020) also permanently authorized buprenorphine telehealth initiation for non-OTP practitioners under specified conditions.

These flexibilities are particularly valuable in rural Georgia where in-person OTP access is limited.

Georgia OTP landscape

State licensure and oversight

Georgia OTPs are licensed by the Georgia Department of Behavioral Health and Developmental Disabilities (DBHDD) under O.C.G.A. §37-7 (substance abuse treatment facilities). DBHDD:

• Licenses OTPs as substance abuse outpatient treatment programs
• Conducts annual state inspections
• Reviews patient complaints
• Coordinates with SAMHSA for federal certification
• Administers state opioid response grants

DBHDD contact: 404-657-2252.

Federal funding through SOR grants

Georgia receives substantial federal funding through:

• State Targeted Response (STR) grants (2017-2019)
• State Opioid Response (SOR) grants (2018-present, periodically renewed)

These grants fund MAT expansion, naloxone distribution, recovery support services, and prevention programs. SOR funds have supported OTP expansion in rural Georgia counties through mobile medication units and brick-and-mortar facility development.

Georgia OTP distribution (approximate 2026)

Rural access gaps and mobile units

Many Georgia counties (particularly in southern Georgia and Appalachian north Georgia) have no OTP within 60 miles. Solutions:

• Mobile Medication Units (MMUs): SAMHSA's MMU rule (effective 2021) allows OTPs to operate mobile units bringing methadone dosing to rural areas. Georgia has approximately 4-5 mobile units as of 2026.
• Take-home doses: Stable patients can receive 14-28 days of take-home methadone, reducing trip frequency
• Office-based buprenorphine: Since MAT Act 2022 X-waiver elimination, any DEA-registered practitioner can prescribe buprenorphine, expanding access
• Telehealth counseling: Permitted under SAMHSA February 2024 rule

Six worked examples for Georgia beneficiaries

Example one: Margaret 68 Atlanta long-term methadone maintenance

Margaret is a 68-year-old retired nurse in Atlanta. She developed OUD after prescription opioid treatment for back surgery in 2010. She has been on methadone maintenance for 8 years at an Atlanta MAT clinic. Her current dose is 90 mg/day. She is stable and has earned 14 days of take-home doses.

Weekly OTP billing:

• HCPCS G2067 (methadone weekly bundle): approximately $195 per week
• Geographic adjustment applies to Atlanta locality
• Medicare pays $195 to the OTP
• Margaret pays $0 (no cost-sharing for OTP services)

Annual treatment cost to Medicare: approximately $10,140. Margaret's annual out-of-pocket cost: $0. Without the SUPPORT Act 2018 expansion, Margaret would have faced $500-700 per month in self-pay methadone costs, totaling $6,000-8,400 per year.

Example two: Robert 72 Savannah newly-diagnosed OUD intake bundle

Robert is a 72-year-old retired shipping clerk in Savannah. He developed OUD after fentanyl use following a workplace injury. He has tried to quit on his own multiple times unsuccessfully. His primary care physician refers him to a Savannah OTP.

Week 1 (intake):

• HCPCS G2076 (methadone intake bundle): approximately $310
• Includes initial medical assessment, comprehensive history, treatment planning
• Daily observed dosing begins
• 4 counseling sessions (individual and group)

Weeks 2-8 (continuing maintenance):

• HCPCS G2067 (methadone weekly bundle): approximately $195/week × 7 = $1,365
• Daily observed dosing
• Weekly individual counseling
• Toxicology screening at weeks 2, 4, 6, 8

Total 8-week initial treatment cost to Medicare: approximately $1,675. Robert pays $0.

After 8 weeks of stable progress, Robert begins earning limited take-home doses based on the SAMHSA February 2024 take-home framework.

Example three: Linda 65 Macon buprenorphine-naloxone sublingual

Linda is a 65-year-old in Macon. She has had OUD for 12 years. She has anxiety about daily OTP visits and prefers buprenorphine-naloxone (Suboxone) over methadone.

Two pathways:

Pathway A: OTP-dispensed buprenorphine

• HCPCS G2068 (buprenorphine sublingual weekly bundle): approximately $230/week
• OTP dispenses the buprenorphine, provides counseling and drug testing
• Linda visits the OTP weekly for medication pickup
• Medicare pays $230; Linda pays $0

Pathway B: Office-based buprenorphine prescribing

• Linda's primary care physician prescribes buprenorphine (now permissible without X-waiver under MAT Act 2022)
• The medication is filled at a community pharmacy under Part D
• Linda pays the Part D copay (typically $5-30 depending on plan and tier)
• Linda pays normal Part B 20% coinsurance for physician visits

Pathway A: $0 out of pocket, but requires weekly OTP visits. Pathway B: Standard cost-sharing (perhaps $20-50/month total), but allows continuity with established primary care physician.

Linda chooses Pathway B because her primary care physician completed the SUPPORT Act 8-hour SUD training and is comfortable managing her treatment.

Example four: Charles 70 Augusta naltrexone injectable extended-release

Charles is a 70-year-old in Augusta who completed inpatient detoxification at AU/Wellstar MCG (10 days opioid-free). His treatment team recommends naltrexone extended-release (Vivitrol) for relapse prevention rather than agonist therapy because Charles is highly motivated and wants to avoid opioid agonists entirely.

Two pathways:

Pathway A: OTP-administered Vivitrol

• HCPCS G2074 (naltrexone injectable monthly): approximately $1,650/month
• OTP administers the monthly injection
• Medicare pays $1,650; Charles pays $0
• Includes counseling and toxicology screening as bundled services

Pathway B: Office-based Vivitrol

• Charles's primary care physician administers Vivitrol in office
• Part B drug coverage (Vivitrol is Part B when administered by physician)
• Standard 20% coinsurance applies (~$330 per dose)
• Medigap pays the 20%

Charles chooses Pathway A through a nearby Augusta OTP. The $0 cost-sharing saves him approximately $4,000 annually compared to Part B physician-office administration with Medigap (which still leaves the deductible portion).

Example five: Patricia 67 Columbus rural mobile medication unit

Patricia is a 67-year-old in rural Stewart County, approximately 35 miles south of Columbus. The nearest OTP is in Columbus. Patricia has OUD and would benefit from methadone, but daily 70-mile round trips are not feasible at her age.

The Columbus OTP operates a Mobile Medication Unit (MMU) under the SAMHSA Mobile Medication Unit rule. The MMU travels to a designated location in Stewart County twice per week to dispense methadone to rural patients.

Patricia's schedule:

• Two visits per week to the MMU pickup site (5 miles from her home)
• Receives methadone for 3-4 days at each visit (under take-home dose framework)
• Weekly telehealth counseling sessions with the OTP counselor
• Quarterly in-person visits to the Columbus OTP for comprehensive medical reviews

Weekly OTP billing:

• HCPCS G2067 (methadone weekly bundle): approximately $195
• HCPCS G2078 (take-home methadone supply add-on)
• Medicare pays the appropriate bundle plus add-on
• Patricia pays $0

The MMU model reduces Patricia's effective travel from 70 miles per day (490 miles per week) to approximately 10 miles per week, a 98% reduction. This rural access innovation, made possible by the 2021 SAMHSA MMU rule and the 2024 telehealth expansion, has meaningfully improved methadone access in southwest Georgia.

Example six: Henry 75 Dalton drives to nearest OTP

Henry is a 75-year-old in Dalton (Whitfield County, far northwest Georgia). The nearest SAMHSA-certified OTP is in Chattanooga TN approximately 30 miles north, or in Marietta GA approximately 90 miles south. Out-of-state OTP visits are permissible but Medicare prefers in-state billing.

Henry has OUD and his physician recommends MAT. Options:

1. Travel to a Cobb County (Marietta) OTP: 90 miles each way, impractical
2. Cross-state to a Chattanooga OTP enrolled with Medicare: 30 miles each way, more feasible
3. Office-based buprenorphine prescription from local primary care physician: most accessible
4. Wait for SOR grant expansion to add a Dalton-area OTP

Henry chooses option 3: office-based buprenorphine. His primary care physician completed SUD training under SUPPORT Act 2018 and is comfortable prescribing buprenorphine. The X-waiver elimination under MAT Act 2022 made this possible. Before January 12, 2023, Henry's physician would have needed special DEA registration and 8-hour X-waiver training.

Henry fills the prescription at a Dalton pharmacy under Part D. He pays the Part D copay ($15 for tier 2 generic Suboxone) and the 20% Part B coinsurance for his quarterly physician visits. Total out-of-pocket: approximately $300 per year (Part D copays + Part B coinsurance with no Medigap), compared to $0 if Henry could access a Medicare-enrolled OTP. The X-waiver elimination dramatically expanded rural buprenorphine access.

Fourteen common mistakes Georgia beneficiaries make

Mistake one: not knowing OTP services are covered

Many Medicare beneficiaries with OUD do not know that Medicare has covered OTP services since January 1, 2020. They may have heard from peers (or pre-2020 information sources) that methadone is not covered.

Mistake two: assuming cost-sharing applies

Some beneficiaries assume the standard 20% Part B coinsurance applies and avoid treatment due to perceived cost. OTP services have $0 cost-sharing. There is no coinsurance and the deductible does not apply.

Mistake three: confusing OTP and office-based buprenorphine

OTP billing (G2067-G2080) applies ONLY to services furnished at a SAMHSA-certified OTP. Office-based buprenorphine (in a physician's office, NOT at an OTP) is billed under standard Part B physician services (E&M codes) plus Part D for the medication. Beneficiaries pay normal cost-sharing for office-based treatment.

Mistake four: trying to fill methadone at a community pharmacy

Methadone for OUD cannot be filled at community pharmacies. It is dispensed only at OTPs (federal law, 21 CFR 1306.07). Some beneficiaries attempt to fill prescriptions at pharmacies and are turned away. Methadone for pain (different indication) can be filled at pharmacies; methadone for OUD cannot.

Mistake five: missing OTP Medicare enrollment status

Some OTPs that were operational pre-2020 enrolled with Medicare in 2019-2020, but a few have not enrolled or have lapsed enrollment. Beneficiaries should verify the OTP is Medicare-enrolled before initiating treatment by calling Medicare 1-800-MEDICARE.

Mistake six: not understanding take-home dose rules

SAMHSA take-home dosing rules were substantially liberalized by the February 2024 Final Rule. Stable patients can earn 14-28 days of take-home doses. Beneficiaries should ask their OTP about take-home eligibility to reduce travel burden.

Mistake seven: discontinuing MAT prematurely

Long-term MAT (12+ months, often years) has the strongest evidence base for sustained recovery. Premature discontinuation within 6 months is associated with high relapse rates and overdose risk. Beneficiaries should discuss duration with the OTP medical director rather than tapering on their own.

Mistake eight: not addressing co-occurring mental health conditions

Many beneficiaries with OUD also have depression, anxiety, PTSD, or other mental health conditions. The OTP bundle covers SUD counseling but not full mental health treatment for other conditions. Beneficiaries should access Medicare mental health benefits (Part B Section 1861(s)(2)(M)) for co-occurring disorders.

Mistake nine: confidentiality concerns deterring treatment

42 CFR Part 2 provides strong confidentiality protection. SUD records cannot be used in criminal proceedings without a court order specifically authorizing the disclosure (subpoena alone is insufficient). Beneficiaries who fear stigma or legal consequences should know the protection is substantial.

Mistake ten: not verifying Medicare Advantage OTP coverage

MA plans must cover OTP services at parity with Original Medicare. However, MA plans may impose network restrictions. Beneficiaries should verify the OTP is in the MA plan's network before treatment.

Mistake eleven: misunderstanding the bundle scope

The OTP weekly bundle covers OTP-furnished services. It does NOT cover services from other providers (primary care, specialty care, emergency department). Those are billed separately under appropriate Part B or Part A benefits.

Mistake twelve: not coordinating MAT with other healthcare

MAT can interact with other medications (notably opioid analgesics for pain, benzodiazepines, certain antibiotics like ciprofloxacin that affect methadone metabolism). Beneficiaries should inform all prescribers about MAT enrollment. The OTP can provide a wallet card identifying MAT status with patient consent.

Mistake thirteen: ignoring referral to community supports

OTPs typically provide warm handoff to community recovery supports (Narcotics Anonymous, SMART Recovery, peer recovery specialists). Treatment retention improves with engagement beyond the OTP itself.

Mistake fourteen: assuming opioid-free is the only goal

MAT is not "trading one addiction for another." Methadone and buprenorphine produce no euphoria at therapeutic maintenance doses. They restore normal opioid receptor function and allow patients to function normally. The goal is recovery and functioning, not opioid-free status.

Resources Brevy connects you with

At Brevy, we maintain comprehensive resources at brevy.com to help Georgia families navigate Medicare coverage of opioid use disorder treatment, locate SAMHSA-certified OTPs, understand the MAT medication options, and access the confidential support that beneficiaries deserve. The SUPPORT Act of 2018 closed a coverage gap that had cost lives for decades, and the MAT Act of 2022 expanded buprenorphine access by eliminating the X-waiver. Georgia beneficiaries with opioid use disorder now have unprecedented access to evidence-based treatment with $0 cost-sharing at SAMHSA-certified OTPs across the state.

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Does Medicare cover Opioid Treatment Program services?

Yes. Section 1861(jjj) of the Social Security Act, added by SUPPORT Act 2018 Section 2005, established Medicare coverage of OTP services effective January 1, 2020. The benefit is implemented at 42 CFR 410.67 and pays OTPs a weekly bundled payment using HCPCS G2067 through G2080.

How much does Medicare pay for OTP services?

OTP services have ZERO beneficiary cost-sharing. The Part B deductible does not apply and there is no 20% coinsurance. The beneficiary pays $0 out of pocket. Medicare pays the entire weekly bundled payment to the OTP.

What is included in the weekly OTP bundle?

The bundle includes:

• MAT medication (methadone, buprenorphine, or naltrexone)
• Drug testing (toxicology screening)
• Individual counseling
• Group counseling
• Substance use counseling
• Intake activities (for week 1)
• Periodic assessments

What is HCPCS G2067?

HCPCS G2067 is the methadone weekly bundle code. The OTP bills G2067 once per week for each beneficiary receiving methadone maintenance. The approximate 2026 Georgia payment is $185-210 per week.

What is the difference between G2067 and G2076?

G2067 is the continuing methadone weekly bundle (used week 2 onward). G2076 is the methadone intake bundle (used for week 1 only, includes initial assessment, treatment planning, and orientation activities in addition to the standard weekly services).

Why is the OTP benefit zero cost-sharing when other Part B benefits have 20% coinsurance?

CMS established zero cost-sharing for OTP services because cost barriers contribute to treatment discontinuation and overdose risk. The public health benefit of full-utilization OTP access outweighs the cost-shifting that beneficiary coinsurance would produce. Only a handful of Part B benefits have zero cost-sharing: OTP services, the Annual Wellness Visit, USPSTF Grade A and B preventive services, and the Medicare Diabetes Prevention Program.

What is an Opioid Treatment Program?

An OTP is a SAMHSA-certified facility that provides medication-assisted treatment for OUD. OTPs are certified under 42 CFR Part 8, accredited by an approved accreditor (CARF, Joint Commission, or COA), and DEA-registered for opioid agonists. OTPs are the only authorized sites for dispensing methadone for OUD treatment.

How is methadone different from other OUD medications?

Methadone is a full opioid agonist (long-acting, Schedule II) that can only be dispensed at SAMHSA-certified OTPs. Buprenorphine is a partial agonist (Schedule III) that can be dispensed at OTPs or community pharmacies. Naltrexone is an antagonist (not controlled) that can be prescribed by any practitioner.

What is the MAT Act of 2022?

The Mainstreaming Addiction Treatment (MAT) Act of 2022, enacted as part of the Consolidated Appropriations Act of 2023, eliminated the DATA 2000 X-waiver requirement for buprenorphine prescribing effective January 12, 2023. Any DEA-registered practitioner can now prescribe buprenorphine for OUD without special registration.

What was the DATA 2000 X-waiver?

The Drug Addiction Treatment Act of 2000 required physicians to obtain a special DEA registration ("X-waiver") to prescribe buprenorphine for OUD. The waiver required 8-hour training and patient panel limits. Only 7% of U.S. physicians obtained the waiver, severely limiting access. MAT Act 2022 eliminated the waiver.

Can my primary care physician prescribe buprenorphine?

Yes. Since January 12, 2023 (MAT Act 2022 effective date), any DEA-registered practitioner can prescribe buprenorphine for OUD. No special X-waiver or 8-hour training is required (though one-time SUD training under SUPPORT Act 2018 applies broadly to all DEA registrants).

What is 42 CFR Part 2?

42 CFR Part 2 provides heightened confidentiality protection for substance use disorder treatment records, more stringent than HIPAA. Specifically, SUD records cannot be used in criminal proceedings without a court order specifically authorizing the disclosure. The SAMHSA Final Rule of February 2024 modernized 42 CFR Part 2 to align more closely with HIPAA while preserving criminal-proceedings protection.

Are OTP services confidential?

Yes. OTPs are subject to 42 CFR Part 2 (heightened SUD confidentiality) in addition to HIPAA. Records cannot be released to third parties without patient consent (with limited exceptions for treatment-payment-operations, emergency care, and other specified circumstances).

Can I receive OTP services via telehealth?

Many OTP services can be furnished via telehealth, including counseling, periodic assessments, and (under the SAMHSA February 2024 rule) buprenorphine initiation via audio-only or audio-video, and methadone initiation via audio-video. Methadone dosing itself requires in-person dispensing or take-home doses (the medication must be physically transferred).

What are take-home doses?

Take-home methadone doses are unsupervised doses the beneficiary takes home rather than receiving observed daily dosing at the OTP. Under the SAMHSA February 2024 rule:

• 30 days of dose stability: up to 14 take-home doses
• 60 days of dose stability: up to 28 take-home doses

Take-home eligibility is determined by the OTP medical director based on individualized assessment.

How do I find an OTP in Georgia?

Call SAMHSA's National Helpline at 1-800-662-HELP (4357) for OTP locations. Use the SAMHSA online treatment locator at findtreatment.samhsa.gov. Call Medicare 1-800-MEDICARE for Medicare-enrolled OTPs. Georgia has approximately 55-60 SAMHSA-certified OTPs concentrated in metro Atlanta, Augusta, Savannah, Macon, Columbus, Albany, and Valdosta.

What if there's no OTP near me?

Options include:

1. Mobile Medication Units (MMUs) that travel to rural areas (Georgia has 4-5 MMUs)
2. Take-home methadone doses (after earning stability) reducing trip frequency
3. Office-based buprenorphine from a local primary care physician (broadly available since MAT Act 2022)
4. Telehealth counseling combined with periodic in-person OTP visits
5. Naltrexone injectable from local physician (monthly injection, less burden)

Does Medicare Advantage cover OTP services?

Yes. Medicare Advantage plans must cover OTP services at parity with Original Medicare. The $0 cost-sharing applies. However, MA plans may impose network restrictions. Beneficiaries should verify the OTP is in the MA plan's network.

What is the difference between methadone for pain and methadone for OUD?

Methadone has two FDA-approved indications: chronic pain and OUD. Different federal rules apply:

• Methadone for chronic pain: prescribed by any DEA-registered physician, filled at any community pharmacy (Schedule II)
• Methadone for OUD: dispensed ONLY at SAMHSA-certified OTPs, cannot be filled at community pharmacies

The same medication is regulated differently based on indication.

Can I be on MAT and continue to work?

Yes. Methadone and buprenorphine at therapeutic maintenance doses do not produce euphoria or impairment in maintenance patients. Most patients on MAT work, drive, and function normally. Some specialized occupations may have additional restrictions; check with the employer's substance use program.

What if I need surgery while on MAT?

Inform the surgical team about MAT enrollment. Methadone and buprenorphine interact with other opioid analgesics. The OTP can communicate with the hospital pharmacy and anesthesiology team to coordinate perioperative pain management. Generally, MAT should be continued during surgery, with additional pain medication added as needed.

How long should I stay in MAT?

Long-term MAT (12+ months, often years) has the strongest evidence base for sustained recovery. There is no fixed duration; decisions about continuation, tapering, or discontinuation should be made with the OTP medical director based on individual response, life circumstances, and stability. Premature discontinuation increases relapse and overdose risk.

How much does it cost to stay on MAT for a year?

If furnished through a Medicare-enrolled OTP under the weekly bundled payment: $0 to the beneficiary. Medicare pays the OTP approximately $10,140 per year for methadone maintenance ($195/week × 52 weeks), but the beneficiary has zero cost-sharing.

If furnished through office-based buprenorphine: standard Part B and Part D cost-sharing applies. Annual out-of-pocket varies based on plan but typically $200-500 total.

Can I appeal an OTP denial?

Yes. The standard Medicare appeals process applies for OTP service denials: redetermination, reconsideration, ALJ hearing, MAC review, federal court. Denials are rare given the broad coverage scope, but possible for missing documentation, lapsed OTP enrollment, or other administrative issues.

Where can I get help with addiction in Georgia?

• SAMHSA National Helpline: 1-800-662-HELP (4357), 24/7, free, confidential, English/Spanish
• Georgia Crisis and Access Line: 1-800-715-4225, 24/7 mental health and SUD crisis support
• GeorgiaCares SHIP: 1-866-552-4464 for Medicare counseling
• Georgia Council on Substance Abuse: 404-523-3440 for advocacy and information
• 988 Suicide and Crisis Lifeline: 988 for crisis support including overdose risk :::

Disclaimers

This guide is provided for educational purposes by Brevy. It is not legal, medical, or substance use treatment advice. Federal regulations at 42 CFR 410.67, 42 CFR Part 8, and 42 CFR Part 2 are authoritative for Medicare OTP coverage, SAMHSA OTP certification, and SUD records confidentiality. Section 1861(jjj) of the Social Security Act is the statutory authority. SUPPORT Act 2018 Section 2005 established the benefit. MAT Act 2022 (enacted in CAA 2023) eliminated the DATA 2000 X-waiver. For specific coverage questions, contact Medicare 1-800-MEDICARE or Palmetto GBA 1-877-567-9230.

For OUD treatment information, contact the SAMHSA National Helpline at 1-800-662-HELP (4357). For crisis support, contact the 988 Suicide and Crisis Lifeline. For Georgia substance use treatment licensing and oversight, contact the Georgia Department of Behavioral Health and Developmental Disabilities at 404-657-2252.

Medication-assisted treatment is a clinical decision made by qualified medical practitioners based on individual assessment. This guide does not recommend specific treatment modalities. Beneficiaries should consult licensed addiction medicine specialists, OTP medical directors, or qualified prescribing physicians for individual treatment recommendations.

Coverage rules and payment amounts described reflect federal policy in effect as of May 2026 and may change through future CMS rulemaking, SAMHSA rulemaking, or congressional action. Beneficiaries should verify current rules at the time of service.

42 CFR Part 2 confidentiality protection is substantial but not absolute. Beneficiaries with specific legal concerns should consult an attorney familiar with substance use disorder law. Atlanta Legal Aid (404-377-0701) and Georgia Legal Services Program (1-800-498-9469) provide free legal assistance for low-income individuals.

::: cta Contacts for Georgia Medicare Opioid Treatment Program Services

• DCH Medicaid Member Services: 1-866-211-0950
• Medicare: 1-800-MEDICARE (1-800-633-4227)
• Palmetto GBA Jurisdiction J: 1-877-567-9230
• GeorgiaCares SHIP: 1-866-552-4464
• SAMHSA National Helpline: 1-800-662-HELP (4357), 24/7 confidential
• Georgia Department of Behavioral Health and Developmental Disabilities: 404-657-2252
• Georgia Crisis and Access Line: 1-800-715-4225
• Georgia Council on Substance Abuse: 404-523-3440
• 988 Suicide and Crisis Lifeline: 988
• DEA Registration: 1-800-882-9539
• Kepro QIO: 1-844-455-8708
• Atlanta Legal Aid: 404-377-0701
• Georgia Legal Services Program: 1-800-498-9469
• 211 Georgia: 211
• Eldercare Locator: 1-800-677-1116
• VA Benefits (substance use treatment): 1-800-827-1000
• HHS OCR: 1-800-368-1019
• Medicare Rights Center: 1-800-333-4114
• Center for Medicare Advocacy: 1-860-456-7790
• Social Security: 1-800-772-1213 :::