Site of service (telecommunications)

30.5 - Site of service (telecommunications) (Rev. 13147; Issued: 03-28-25; Effective: 01-01-25; Implementation: 03-25-25) During the Public Health Emergency (PHE) for the COVID-19 pandemic, CMS allowed various flexibilities for OUD treatment services furnished by OTPs via communication technology, including allowing the therapy and counseling portions of the weekly bundles of services furnished by OTPs, additional counseling or therapy payable under the add-on code for additional counseling or therapy, the OTP intake add-on code for the initiation of treatment with buprenorphine, and periodic assessments to be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology if beneficiaries did not have access to two-way audio/video communications technology, provided all other applicable requirements were met. This included instances when the beneficiary was not capable of, or does not consent to, the use video technology for the service. All these aforementioned flexibilities have been made permanent either during the COVID-19 PHE or following the PHE which ended May 11, 2023. In total, CMS allows the following flexibilities for use of communication technology for OUD treatment services furnished by OTPs, as clinically appropriate and in compliance with all applicable requirements: • Two-way interactive audio-video communication technology o Substance use counseling and individual and group therapy services included in the bundled payment o The add-on code for additional counseling and therapy o Periodic assessments o Initiation of treatment with buprenorphine if authorized by DEA and SAMHSA at the time the service is furnished o Initiation of treatment with methadone if authorized by DEA and SAMHSA at the time the service is furnished • Audio-only communication technology, if beneficiaries do not have access to two-way audio- video communications technology, including instances when the beneficiary is not capable of, or does not consent to, the use of video technology for the service: o Substance use counseling and individual and group therapy services included in the bundled payment o The add-on code for additional counseling and therapy o Periodic assessments o Initiation of treatment with buprenorphine if authorized by DEA and SAMHSA at the time the service is furnished Beginning January 1, 2025, OTPs may bill the OTP intake add-on code (HCPCS code G2076) when used for the initiation of treatment with methadone when furnished via two-way audio-video communications technology. This is permitted if an OTP practitioner determines that an adequate evaluation of the patient can be accomplished through audio-video communication technology, to the extent that the use of audio-video telecommunications technology to initiate treatment with methadone is authorized by DEA and SAMHSA at the time the service is furnished, and all other applicable requirements are met. OTPs may bill the OTP intake add-on code (HCPCS code G2076) for the use of audio-only initiation of treatment with methadone if pursuant to the exception specified in § 8.12(f)(2)(v)(A), which allows for the use of audio-only devices when the patient is in the presence of a licensed practitioner who is registered to prescribe (including dispense) controlled medications, and when audio-visual technologies are not available or their use is not feasible for a patient. The licensed practitioner would need to be present in the same room as the patient and be available to conduct the visual component of the examination. OTPs providing intensive outpatient services to Medicare beneficiaries with an OUD shall not receive payment under Medicare part B if these services are furnished via audio-video or audio-only communications technology. CMS expects OTPs to add Modifier 93 (Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system) to the claim for counseling and therapy provided via audio-only telecommunications using HCPCS code G2080, as well as for intake activities and periodic assessments furnished using audio-only communication technology. Additionally, CMS expects OTPs to add Modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) to the claim for counseling and therapy provided via audio-video telecommunications using HCPCS code G2080, as well as for intake activities and periodic assessments furnished using audio and video communication technology. As OTP services are not PFS services, no originating site facility fee (HCPCS code Q3014) applies to OUD treatment services, and OTPs are not authorized to bill for the originating site facility fee. Additionally, the payment for the substance use counseling and individual and group therapy are included in the bundled payment rates made to OTPs; therefore, the practitioner furnishing the service remotely should not bill separately for the service.