Medicare could have saved $301.5 million if bundled payments for opioid use disorder (OUD) treatments were better matched to the services actually provided to patients.

That’s equivalent to 53% of the total payments in this space of $564.6 million, according to an audit by the Office of Inspector General (OIG).

For the audit, the OIG reviewed a sample of 100 claim lines from 79 different opioid treatment programs (OTPs) and requested that the OTPs identify all OUD treatment services they provided to a Medicare enrollee during the episode of care, along with documentation of those services. 

Based on this sample set of claims data, the OIG found that “the bundled payments generally exceeded the OIG-calculated payment amounts because CMS’s methodology to determine the bundled payment rates did not reflect the combination of specific OUD treatment services and the frequency of treatment services that OTPs provided to enrollees during an episode of care.”

Following this discovery, the OIG recommended that the Centers for Medicare and Medicaid Services use the audit data to pay closer attention to the combination of OUD treatment services and the frequency with which they are provided to Medicare patients. This was the only recommendation CMS agreed with.

The agency also urged CMS to “consider revising its methodology for determining the nondrug component of weekly bundled payment rates,” by developing additional codes for medication and counseling services provided during an episode of care.

CMS did not concur with this because under current legislation, it “does not believe it is appropriate” to develop additional codes for weekly bundles, but stated it would “continue to consider the accuracy of the rates for future rulemaking.”

OIG also suggested that CMS more closely monitor activities to ensure Medicare makes bundled payments only in instances where OTPs have “properly documented OUD treatment services in enrollees’ treatment plans.”

However, CMS also disregarded this suggestion, stating that treatment plans are required only by the Substance Abuse and Mental Health Services Administration (SAMHSA), but not a CMS payment requirement. 

Several reports have surfaced this year from the OIG, painting a picture of how OUDs impact the Medicare patient population. 

Fewer than one in five Medicare enrollees receive medication-assisted treatment (MAT) for their OUDs and among those who do, only around 40% who start treatment with an MAT like buprenorphine continue treatment.