Nearly 80% of Opioid Treatment Services to Medicaid Beneficiaries in CO Did Not Meet Federal and State Requirements

A federal audit of Colorado’s OTP services to determine whether the state’s oversight ensured that Medicaid OTP services in Colorado met Federal and State requirements found that nearly 80% of services sampled did not meet those requirements.

“On the basis of our sample results, we estimated that over 1.1 million OTP services, or about 79 percent, did not meet Federal and State requirements during the audit period,” a report from the U.S. Department of Health and Human Services read.

The federal government found Colorado’s biennial audits that were conducted by the State Opioid Treatment Authority (SOTA) were not sufficient enough in scope, therefore leaving vulnerabilities in the system. The state-run audits also lacked “depth of coverage to ensure that OTPs maintained a recordkeeping system that was adequate to document and monitor patient care, or to ensure that OTP services met Federal and State requirements.”


The biennial audits of each OTP were conducted by a single person and that person covered about 10% of patient charts. The audits took between one and two days to complete, which the federal government said in its report was not an adequate review, especially “for one person to be able to thoroughly review patient charts for deficiencies and to devote sufficient time to other tasks.”

The opioid epidemic still rages on in the U.S. and the federal government has deemed it a national public health emergency.

“The high potential for misuse of opioids has led to alarming trends across the country, including record numbers of people developing opioid use disorders,” according to the federal report. “In 2019, there were nearly 50,000 opioid-related overdose deaths in the United States.”


OTP’s are designed to provide medication coupled with counseling services for people diagnosed with an opioid use disorder. If those OTPs are not properly operated, patients suffer.

Following the audit, the HHS recommended Colorado strengthen its biennial audits of OTPs to ensure that services are in accordance with Federal and State requirements. It also recommended that recordkeeping, education on the deficiencies the federal government found and increasing their “awareness of compliance issues regarding Federal and State requirements” are all necessary steps moving forward.

In turn, Colorado reported to the federal government it had hired a program coordinator to support the SOTA in conducting the biennial audits, provide technical assistance to OTPs and manage the Central Registry (a system used to ensure that individuals are not enrolled in more than one OTP).

Written by Patrick Filbin