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Ahead of formal rulemaking for 2027, ASAM has urged the Centers for Medicare & Medicaid Services (CMS) to update Medicare payment and coding policies for outpatient substance use disorder (SUD) treatment to reflect advances in treatment standards.  

In a letter to CMS Administrator Oz, ASAM applauded past efforts to expand access, but highlighted that several issues necessitated the need to update existing codes, including changes in The ASAM Criteria, the absence of codes to appropriately describe medically managed outpatient treatment, and data showing that millions of Medicare beneficiaries continue to lack access to treatment. 

This problem is exacerbated by current Medicare payment rates for these services that are setting-specific. Currently, Medicare pays nearly 40% less for outpatient SUD treatment services when delivered in non-OTP (opioid treatment program) settings compared to OTPs—even though the services are essentially identical aside from methadone dispensing and extensive federal regulations in the case of OTPs. These reduced payments in non-OTP settings underscore the fact that far fewer Medicare beneficiaries in non-OTP settings appear to be initiating outpatient treatment for SUD, compared to treatment services in OTPs where service utilization among Medicare beneficiaries remains robust. This inequity makes it financially unsustainable for many non-OTP outpatient practices to offer comprehensive SUD treatment, further restricting Medicare beneficiaries' access to sustainable recovery. 

ASAM encouraged CMS to address these issues by establishing a more robust monthly bundled payment for non-OTP outpatient settings with reasonable safeguards against inappropriate use, similar to the existing model for OTPs. ASAM also urged CMS to strengthen support for addiction specialist physicians (ASPs) by reviewing and updating codes for interprofessional consultation services to ensure ASP expertise is appropriately recognized and integrated into care teams. 

Read the letter

Read ASAM's additional recommendations to fix burdensome regulations impacting addiction care.