Opioid Treatment Program Telehealth Billing: What the Intake Payment Represents

Opioid treatment program telehealth intake billing uses a separate Medicare payment for a new patient’s initial medical examination and care plan, added to the program’s weekly treatment bundle. An intake coordinator may know who evaluated the patient. A biller may see the charge without seeing that work. In a telehealth billing fraud review, we connect the intake claim to the examination, the clinician and the decision to bill.

What Does the Weekly Opioid Treatment Program Bundle Pay For?

Medicare pays enrolled opioid treatment programs for weekly episodes of opioid use disorder treatment. The bundle combines a drug component, when medication is provided, with a non-drug component covering the other treatment services in the patient’s plan. Those services include dispensing or administering medication, substance use counseling, individual and group therapy, and toxicology testing when performed.

The program itself has to qualify for Medicare payment. The Centers for Medicare & Medicaid Services requires Medicare enrollment, certification by the Substance Abuse and Mental Health Services Administration, and accreditation by a body that administration approves.

The agency’s opioid treatment program billing guidance requires at least one service from the drug or non-drug component during the week covered by the episode. A week without medication uses the non-drug bundle and requires a service from that component.

The weekly bundle codes identify the treatment Medicare is paying for: G2067 for methadone, G2068 for oral buprenorphine and G2074 for a week without medication. Intake and periodic assessment have their own add-on payments, billed alongside a weekly bundle. A biller sees both the ongoing treatment and the additional work claimed for that patient.

What Does G2076 Pay For?

G2076 pays for the intake work a new patient needs when starting treatment at a Medicare-enrolled opioid treatment program. The Centers for Medicare & Medicaid Services’ final intake description includes an initial medical examination by an appropriately licensed practitioner and preparation of a care plan. The examination and the planning are the clinical work behind the additional payment.

The care plan includes the patient’s goals and agreed actions to reach them, including harm reduction. It addresses needs such as housing, employment and recovery support that the patient wishes to pursue. A social-needs assessment may inform that plan. For someone working in intake, these are recognizable conversations about what will help the patient stay in treatment.

The rule also identifies who can do the work. It assigns the initial medical examination to an appropriately licensed practitioner and describes the planning work as performed by appropriately licensed or credentialed personnel. A program’s appointment calendar can identify the planned encounter, while the clinical record identifies the assessment and plan that actually followed.

The Centers for Medicare & Medicaid Services limits the intake payment to new patients starting treatment at that opioid treatment program. It expressly bars repeated intake billing for existing patients, including when another social-needs assessment occurs. We see the absurdity in calling the same patient new again just to collect another intake payment. The patient needs continuing care, and Medicare gets another bill for a beginning.

Methadone and Buprenorphine Have Different Intake Rules

The 2025 Medicare final rule permits video intake for methadone when the practitioner can adequately evaluate the patient that way and considers it clinically appropriate. The Drug Enforcement Administration and the Substance Abuse and Mental Health Services Administration must also allow that use of video on the day of the visit.

The rule addresses barriers including unreliable transportation, distance to treatment and work schedules. Remote intake can spare a patient a trip while retaining the clinical evaluation the payment represents. Billing for an examination that was skipped cheats both the patient starting treatment and the taxpayers paying for that health care.

The same rule describes a narrower exception for audio-only methadone intake. When video is unavailable or infeasible, the patient must be in the same room as a licensed practitioner registered to prescribe or dispense controlled medications. That practitioner must be available to conduct the visual component of the examination.

For a patient starting buprenorphine, the Medicare rule permits video intake when clinically appropriate. It also permits phone calls when video is unavailable to the patient and the other applicable requirements are met. The medication, the communication method and the people present all matter to what the program can bill.

An intake record describing a phone call can therefore raise different questions depending on the treatment being started. In a methadone review, who was physically with the patient can be decisive. We examine those facts alongside the prescribing authority applicable to the encounter, because the Medicare payment rule makes that authority a condition of payment.

G2077 Covers the Assessment After Intake

G2077 is the periodic-assessment add-on for continuing treatment. The assessment reviews medication dosing, treatment response, other substance use disorder needs, the patient’s goals, and relevant physical and psychiatric needs. It can build on or adjust the care plan developed at intake.

A new patient entering an opioid treatment program and an existing patient whose treatment needs reassessment represent different clinical events and different add-on codes. The Centers for Medicare & Medicaid Services assigns additional assessments after intake to the periodic-assessment code.

The 2025 final rule also made audio-only periodic assessments a permanent Medicare flexibility beginning January 1, 2025, when the beneficiary lacks access to two-way audio-video technology and all other requirements are met. That permission concerns reassessment during treatment, with its own clinical purpose and conditions.

What the Intake Record and Claim Should Show

The useful evidence connects the work to the claim. For an opioid treatment program intake, that means the patient’s start of treatment, the initial examination, the care plan, the people who performed the work, the communication method and the relevant date. A completed intake questionnaire records information supplied to the program. The clinical record shows how a practitioner evaluated it and what care was planned.

Telehealth operations can divide scheduling, technology, clinical care and billing among different people or businesses. The platform supplies the connection, the practitioner supplies the evaluation, and the enrolled opioid treatment program submits the claim. An insider who understands those handoffs may know why an appointment appeared as completed in billing, or who decided that a later assessment should be charged as intake. Their intake schedules, assessment records, care plans and billing instructions can connect those decisions to the claim.

The dates also need to be read in context. The billing guidance allows the date on an add-on claim to reflect the first day of a standard weekly billing cycle, so that field can differ from the day the clinical work occurred. We connect the actual encounter date and the program’s billing cycle before comparing the claim with the Medicare rules for the service date.

Place of Service 58 identifies the opioid treatment facility on professional claims, including for remote services. The billing guidance also lists modifier 95 for audio-video counseling and therapy and modifier 93 for audio-only counseling and therapy, for service dates on or after May 12, 2023. Those labels give us another comparison with the encounter record: how the business described the connection, and what the patient and practitioner actually used.

The Payment Rule and the Decision to Bill

If you know a program knowingly charged Medicare for intake work that never happened or repeatedly billed existing patients as new intakes, we can assess that conduct with you. Talk with us about reporting the billing practice and the decisions behind the claim. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

When You Know What Happened at Intake

If you work in opioid treatment program intake, clinical operations or billing and know the paid claim tells a different story from the care delivered, talk with our whistleblower experts about the false intake claims. We work beside you to build your strongest case around the examination, the care plan and the billing decisions, and bring in healthcare fraud whistleblower lawyers who understand Medicare payment.