When it comes to ACEP’s long-time goal of expanding the use of medication-assisted treatment (MAT) for the treatment of opioid use disorder (OUD), most of our attention recently has been spent on the “saga” surrounding the X-waiver practice guidelines—which the Trump Administration attempted to put into place but that the Biden Administration decided not to finalize. While we are disappointed with the Biden Administration’s decision, we are hopeful that the administration will follow through on its stated commitment to “examine ways to increase access to buprenorphine, reduce overdose rates and save lives.”
Despite this setback in our effort to “X the X-waiver,” it is important to remember that there have been some great recent developments related to the use of MAT. First, as outlined in a previous Regs & Eggs blog, critical changes to the “Three-day Rule” are still going into effect later this year. Once finalized (hopefully in June), these revisions to the Three-day Rule will allow health care practitioners to dispense a three-day supply of buprenorphine to one person at one time instead of only allowing physicians to administer one-days’ worth of medication to a person at one time over a three-day period.
Furthermore, you as emergency physicians can now start getting reimbursed by Medicare for MAT services you deliver in the emergency department (ED)! This is a policy that ACEP strongly advocated for and help secure in the 2021 Medicare physician fee schedule regulation (the major annual reg that impacts Medicare payments for physicians and other health care practitioners). In that reg, the Centers for Medicare & Medicaid Services (CMS) finalized a proposal to create a new add-on code for MAT (G2213) that can be billed in addition to an ED evaluation and management (E/M) code during an ED visit.
The add-on code became effective on January 1 of this year, so you can start billing for this code now (if you haven’t already)! While this is great news, we definitely understand that you may all have questions about how and when to bill the add-on code. And… we have answers—as ACEP earlier this week published a set of frequently-asked questions (FAQs) about the code!
One of the questions we have frequently heard is what the documentation requirements are for the new code. As emergency physicians, you may not perform all aspects of the code descriptor: “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.” For example, “initiation” of the service for patients will involve a transition of care to other clinicians outside the ED. Fortunately, CMS does not expect you to conduct all these activities, but to “furnish only those activities that are clinically appropriate for the beneficiary that is being treated.” While not specifically required, ACEP believes that a good documentation 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 OUD with an ICD-10 from the F11 family of codes.
This is just one of the FAQs we have in the set, and I encourage you to review them all. Once you do, please let us know if they answer your questions—or if there are other questions you have that you think we should add to the FAQ set. In addition, if you have already used this add-on code, let us know whether you faced any challenges with billing or reimbursement. We are always happy to reach out to CMS if needed to get clarification on any issue you identify. You are welcome to contact me directly (firstname.lastname@example.org) or ACEP’s Reimbursement Director, David McKenzie (email@example.com).
While there are still numerous obstacles to providing MAT to patients with OUD, having a stable reimbursement mechanism for these services definitely helps. We hope that other public and private payors will follow Medicare’s lead, and that all of you soon have the resources and the flexibility you need to provide these critical services to your patients.
Until next week, this is Jeffrey saying, enjoy reading regs with your eggs.