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Medication Assisted Treatment (MAT) FAQs

  • What is Medication Assisted Treatment (MAT)?

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    Answer

    Medication Assisted Treatment (MAT) is the use of medications, such as Buprenorphine or Suboxone, to treat opioid disorders. There was previously not a reimbursement paradigm for MAT in the emergency department (ED), but based on ACEP advocacy, CMS is finalizing its proposal to pay for MAT delivered in the ED starting in 2021.

    Answer

    Medication Assisted Treatment (MAT) is the use of medications, such as Buprenorphine or Suboxone, to treat opioid disorders. There was previously not a reimbursement paradigm for MAT in the emergency department (ED), but based on ACEP advocacy, CMS is finalizing its proposal to pay for MAT delivered in the ED starting in 2021.

  • What documentation is required to report MAT?

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    Answer

    CMS states that one should “should furnish only those activities that are clinically appropriate for the beneficiary that is being treated.” While not specifically noted to be required, a good practice would be to write a note describing the indications for MAT, the specific medications employed, and the follow up process as well as including a diagnosis of opioid use disorder (OUD) with an ICD-10 from the F11 family of codes.

    Answer

    CMS states that one should “should furnish only those activities that are clinically appropriate for the beneficiary that is being treated.” While not specifically noted to be required, a good practice would be to write a note describing the indications for MAT, the specific medications employed, and the follow up process as well as including a diagnosis of opioid use disorder (OUD) with an ICD-10 from the F11 family of codes.

  • How should I report MAT on my ED claims?

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    Answer

    For 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.

    G2213 is valued at 1.89 Total RVUs and 1.30 Work RVUs.

    For 2021, Medicare will pay about $ 65.95, which is between a 99282 and 99283 (ED E/M code levels 2 and 3).

    One can report this code in addition to a regular ED visit (evaluation and management) service.

    Answer

    For 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.

    G2213 is valued at 1.89 Total RVUs and 1.30 Work RVUs.

    For 2021, Medicare will pay about $ 65.95, which is between a 99282 and 99283 (ED E/M code levels 2 and 3).

    One can report this code in addition to a regular ED visit (evaluation and management) service.

  • What is an X-waiver and how does that apply to MAT?

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    Answer

    Currently, physicians need 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). To complete this mandated process, physicians must take an eight-hour training course, apply for the waiver from the federal Substance Abuse and Mental Health Administration, and eventually receive the waiver from the U.S. Drug Enforcement Administration (DEA). Although ACEP has provided an ED-specific waiver training course, we have long argued that this requirement creates a significant barrier to treatment and have advocated for its removal.

    Answer

    Currently, physicians need 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). To complete this mandated process, physicians must take an eight-hour training course, apply for the waiver from the federal Substance Abuse and Mental Health Administration, and eventually receive the waiver from the U.S. Drug Enforcement Administration (DEA). Although ACEP has provided an ED-specific waiver training course, we have long argued that this requirement creates a significant barrier to treatment and have advocated for its removal.

  • Is the x-waiver still required for emergency physicians to prescribe buprenorphine?

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    Answer

    Yes. The X-waiver is still required. On January 14, 2021, HHS did issue draft practice guidelines that effectively eliminate the X-waiver requirement for physicians—and impose no limitations on prescribing buprenorphine for the treatment of opioid use disorder for emergency physicians and other hospital-based physicians. However, in order to for the guidelines to become effective, they had to be officially published in the Federal Register. ACEP supported the guidelines and sent a letter to HHS, co-signed by 15 other organizations, requesting that the Department finalize the guidelines.

    On January 27, 2021, HHS and the Office of National Drug Control Policy (ONDCP) announced that the guidelines were released prematurely and “cannot be issued at this time.” HHS and ONDCP also state that they are “committed to working with interagency partners to examine ways to increase access to buprenorphine, reduce overdose rates and save lives.”

    Answer

    Yes. The X-waiver is still required. On January 14, 2021, HHS did issue draft practice guidelines that effectively eliminate the X-waiver requirement for physicians—and impose no limitations on prescribing buprenorphine for the treatment of opioid use disorder for emergency physicians and other hospital-based physicians. However, in order to for the guidelines to become effective, they had to be officially published in the Federal Register. ACEP supported the guidelines and sent a letter to HHS, co-signed by 15 other organizations, requesting that the Department finalize the guidelines.

    On January 27, 2021, HHS and the Office of National Drug Control Policy (ONDCP) announced that the guidelines were released prematurely and “cannot be issued at this time.” HHS and ONDCP also state that they are “committed to working with interagency partners to examine ways to increase access to buprenorphine, reduce overdose rates and save lives.”

  • If emergency physicians do not have an X-waiver, can they still bill the add on code G2213?

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    Answer

    In order to bill for the add-on code G2213, emergency physicians must furnish services that are clinically appropriate for the patient related to the initiation of MAT in the ED. This includes assessment, referral to ongoing care, and arranging access to supportive services.

    When initiating MAT in the ED, emergency physicians must abide by existing laws and regulations. On the federal level, this includes the X-waiver requirement for prescribing buprenorphine, and the current Three-Day Rule, which allows non-waivered physicians to administer one day’s worth of medication to a patient at one time—over a three-day period.

    It is important to note that the Three-Day Rule will soon be modified. The Easy MAT Act, which was incorporated into a short-term funding bill and signed into law on December 11, 2020, requires the Attorney General (who will delegate this to the Drug Enforcement Agency) to revise the Three-day Rule so that “practitioners, in accordance with applicable State, Federal, or local laws relating to controlled substances, are allowed to dispense not more than a three-day supply of narcotic drugs to one person or for one person’s use at one time for the purpose of initiating maintenance treatment or detoxification treatment (or both).”

     

    Thus, under this new law, practitioners (not just physicians) will be allowed to dispense three-days’ worth of medication at one time instead of only being allowed to administer one day’s worth of medication to a patient at one time over a three-day period. The Drug Enforcement Administration has six months from the date the bill was enacted (meaning six months from December 11, 2020 or June 9, 2021) to issue a regulation that would implement this change. This means that the current Three-day Rule remains in place until at least June.

    Answer

    In order to bill for the add-on code G2213, emergency physicians must furnish services that are clinically appropriate for the patient related to the initiation of MAT in the ED. This includes assessment, referral to ongoing care, and arranging access to supportive services.

    When initiating MAT in the ED, emergency physicians must abide by existing laws and regulations. On the federal level, this includes the X-waiver requirement for prescribing buprenorphine, and the current Three-Day Rule, which allows non-waivered physicians to administer one day’s worth of medication to a patient at one time—over a three-day period.

    It is important to note that the Three-Day Rule will soon be modified. The Easy MAT Act, which was incorporated into a short-term funding bill and signed into law on December 11, 2020, requires the Attorney General (who will delegate this to the Drug Enforcement Agency) to revise the Three-day Rule so that “practitioners, in accordance with applicable State, Federal, or local laws relating to controlled substances, are allowed to dispense not more than a three-day supply of narcotic drugs to one person or for one person’s use at one time for the purpose of initiating maintenance treatment or detoxification treatment (or both).”

     

    Thus, under this new law, practitioners (not just physicians) will be allowed to dispense three-days’ worth of medication at one time instead of only being allowed to administer one day’s worth of medication to a patient at one time over a three-day period. The Drug Enforcement Administration has six months from the date the bill was enacted (meaning six months from December 11, 2020 or June 9, 2021) to issue a regulation that would implement this change. This means that the current Three-day Rule remains in place until at least June.

  • Can a resident prescribe buprenorphine?

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    Answer

    Healthcare practitioners, including physicians, must have a X-waiver from the Drug Enforcement Administration (DEA) to prescribe buprenorphine. Currently, residents are not able to get a DEA X-waiver until they 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 complete the required training and apply for an X-waiver.

    In order to receive a personal DEA number, residents must hold an active license in the state where they are going to practice. If the state requires its own controlled substance permit, they must also obtain this permit as well, or apply for it, before registering with the DEA and receiving a DEA number.

    If a resident does not have an X-waiver, buprenorphine prescriptions have to be signed by the attending, who must have their own X-waiver. If the attending in this situation does not have an X-waiver, the resident would not able to prescribe buprenorphine for the patient.

    Answer

    Healthcare practitioners, including physicians, must have a X-waiver from the Drug Enforcement Administration (DEA) to prescribe buprenorphine. Currently, residents are not able to get a DEA X-waiver until they 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 complete the required training and apply for an X-waiver.

    In order to receive a personal DEA number, residents must hold an active license in the state where they are going to practice. If the state requires its own controlled substance permit, they must also obtain this permit as well, or apply for it, before registering with the DEA and receiving a DEA number.

    If a resident does not have an X-waiver, buprenorphine prescriptions have to be signed by the attending, who must have their own X-waiver. If the attending in this situation does not have an X-waiver, the resident would not able to prescribe buprenorphine for the patient.

Updated February 2021

Disclaimer

The American College of Emergency Physicians (ACEP) has developed the Reimbursement & Coding FAQs and Pearls for informational purposes only.   The FAQs and Pearls have been developed by sources knowledgeable in their fields, reviewed by a committee, and are intended to describe current coding practice. However, ACEP cannot guarantee that the information contained in the FAQs and Pearls is in every respect accurate, complete, or up to date.

The FAQs and Pearls are provided "as is" without warranty of any kind, either express or implied, including but not limited to, the implied warranties of merchantability and fitness for a particular purpose. Payment policies can vary from payer to payer. ACEP, its committee members, authors or editors assume no responsibility for, and expressly disclaim liability for, damages of any kind arising out of or relating to any use, non-use, interpretation of, or reliance on information contained or not contained in the FAQs and Pearls. In no event shall ACEP be liable for direct, indirect, special, incidental, or consequential damages arising out of the use of such information or material. Specific coding or payment related issues should be directed to the payer.

For information about this FAQ/Pearl, or to provide feedback, please contact David A. McKenzie, ACEP Reimbursement Director at (469) 499-0133 or dmckenzie@acep.org.

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