Opioid treatment programs (OTPs) are the door to evidence-based medication for patients with opioid use disorder (OUD).
Current regulations may not be strong enough to keep these facilities in compliance with requirements that prevent overpayment for services and ensure that patients receive the most appropriate treatment.
An audit conducted by the Department of Health and Human Services (HSS) Office of Inspector General (OIG) recently found that, of 100 sampled Massachusetts OTPs, only 74 complied with federal and state requirements.
“The state agency could improve its oversight to OTPs to ensure that they complied with certain federal and state requirements,” the report read. “The state agency had procedures in place to oversee the OTPs, but these procedures were not always strong enough to prevent the errors identified in this report.”
OTPs provide medications for opioid use disorder (MOUD). OTPs are required to be certified and accredited by the Substance Abuse and Mental Health Services Administration (SAMHSA), licensed by their state of operation, and registered with the Drug Enforcement Administration (DEA).
The OIG’s report involved an audit of Medicaid claims for OUD treatment services provided from July 2021 to June 2022.
The most common problem found among Massachusetts OTPs was a failure to regularly review treatment plans with patients.
Massachusetts state regulations require OTPs to review each individual’s treatment plan every three months. Of the sampled OTPs, 23 failed to review treatment plans as often as required; in one instance an OTP did not review a patient’s treatment plan for more than six months.
This failure increases the risk that a patient would receive less effective treatment.
“Specifically, without properly executed reviews and updates of treatment plans, OTPs may be unable to accurately monitor individual needs and, therefore, provide the most optimal care to achieve the desired goals for the individual,” the report read.
The OIG also found that three OTP services failed to document counseling services as required by Massachusetts Medicaid regulations.
Due to this lack of documentation, the report found that Medicaid may have overpaid three OTPs.
To remedy the identified problems, the OIG recommended that Massachusetts follow up with OTP providers and continue procedures to ensure OTP compliance. The report noted that the state agreed with the office’s recommendations and has outlined its plans to take actions that align with these recommendations.
The audit’s findings come after a period of change in the OTP landscape.
For-profit, private equity-backed organizations have increasingly become involved with the OTP industry. In 2011, private equity-backed providers operated 55% of OTPs. That figure rose to 62% in an analysis released earlier this year.
