Medication Assisted Treatment for Opioid Use Disorders – Reporting Requirements

September 29, 2016

On September 27, 2016, the Centers for Medicare and Medicaid Services (CMS) posted a final rule in the Federal Register regarding reporting requirements for practitioners who request an increase in the number of patients (up to 275) for whom they may prescribe medication for treatment of opioid use disorders. 

All practitioners whose Request for Patient Limit Increase is approved under § 8.625 must submit to Substance Abuse and Mental Health Services Administration (SAMHSA) annually a report along with documentation and data, as requested by SAMHSA, to demonstrate compliance with applicable provisions. The report must be submitted within 30 days following the anniversary date of a practitioner’s Request for Patient Limit Increase approval and during this period on an annual basis thereafter or on another annual schedule as determined by SAMHSA.

The report shall include information concerning the following, as further detailed in report form instructions issued by the Secretary:

1. The annual caseload of patients by month.
2. Numbers of patients provided behavioral health services and referred to behavioral health services.
3. Features of the practitioner’s diversion control plan.

SAMHSA may check reports from practitioners prescribing under the higher patient limit against other data sources to the extent allowable under applicable law. If discrepancies between reported information and other data are identified, SAMHSA may require additional documentation from the practitioner.

Failure to submit reports under this section, or deficient reports, may be deemed a failure to satisfy the requirements for a patient limit increase, and may result in the withdrawal of SAMHSA’s approval of the practitioner’s Request for Patient Limit Increase. Click here to view the Federal Register notice.