1. What is Medication Assisted Treatment (MAT)?
Medication Assisted Treatment (more recently referred to as Medications for Opioid Use Disorder or MOUD) is the use of medications, such as Buprenorphine or Suboxone, to treat Opioid Use Disorders (OUDs). Historically, there has not been a reimbursement paradigm for MAT in the emergency department (ED). However, in response to ACEP advocacy, CMS finalized its proposal to pay for MAT delivered in the ED starting in 2021.
2. What documentation is required to report MAT?
CMS states that the physician/QHP “should furnish only those activities that are clinically appropriate for the beneficiary being treated.” While not explicitly required, a good practice would be to write a note describing the indications for MAT, the specific medications employed, the follow-up process, and including a diagnosis of OUD with an ICD-10 from the F11 family of codes.
3. How should I report MAT on my ED claims?
Starting in 2021, add-on code G2213 (Initiation of medication for the treatment of opioid use disorder in the emergency department setting, including assessment, referral to ongoing care, and arranging access to supportive services) is available to report MAT/MOUD.
For 2023, when provided in a facility setting, CMS values G2213 at 1.86 Total RVUs and 1.30 Work RVUs.
For 2023, Medicare will pay about $61.50, which falls between the reimbursement for 99282 and 99283 (ED E/M code levels 2 and 3).
Note: G2213 is an add-on code reported in addition to a regular ED visit (evaluation and management) service.
4. What is an X-waiver and how does that apply to MAT?
Previously, physicians needed to receive an “X-waiver,” as required by the Drug Addiction Treatment Act of 2000 (DATA 2000), in order to prescribe buprenorphine, methadone, or naloxone to patients with OUD in settings other than opioid treatment programs (such as the ED).
At the end of 2022, Congress passed the “Consolidated Appropriations Act, 2023” (Public Law No: 117-328), which repealed the X-waiver requirement. As a part of the Act, Congress also established new training requirements for the treatment of substance use disorder that practitioners need to receive to receive or renew their DEA license. This new requirement starts on June 27, 2023. Please see the following training letter provided by the US Department of Justice. Additional resources may be found at the Department of Justice Website.
5. Is the x-waiver still required for emergency physicians to prescribe buprenorphine?
No, the X-waiver is no longer required for emergency physicians to prescribe buprenorphine.
7. Can a resident prescribe buprenorphine?
Healthcare practitioners, including physicians, must have a Drug Enforcement Administration (DEA) number to prescribe buprenorphine. Residents must have a personal DEA number — as opposed to the "educational limited" DEA license, which is tied to the academic center. Some residents train and practice under their institution or hospital’s DEA number, so they do not obtain their own personal DEA numbers. If a resident physician obtains their own personal DEA license, they may prescribe buprenorphine.
In order to receive a personal DEA number, residents must hold an active license in the state where they will practice. If the state requires a controlled substance permit, they must also obtain it or apply for it before registering with the DEA and receiving a DEA number.
If a resident does not have a personal DEA number, buprenorphine prescriptions have to be signed by the attending.
However, residents may be able to dispense buprenorphine to patients in emergency situations under the “Three-Day Rule.” For more information on the Three Day Rule, please read ACEP’s regulatory blog.
Updated April 2023
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