OFFICE BASE OPIOID TREATMENT

Modified on Thu, 27 Apr, 2023 at 2:00 PM

OFFICE BASE OPIOID TREATMENT

1.1 Definitions

1.1.1 Buprenorphine

Buprenorphine, a synthetic, FDA-approved, derivative of Thebaine, is defined as a Schedule III opioid partial 

agonist that works by blocking the opioid receptors in the brain and is used for both longterm maintenance and for medically supervised detoxification from opioids.

1.1.2 Buprenorphine-Naloxone

Buprenorphine-naloxone is a synthetic, Federal Drug Administration (FDA) approved, Schedule III 

opioid partial agonist combination that works by blocking opioid receptors is the 

preferred formulation for non-pregnant beneficiaries.

Naloxone is included to reduce the diversion potential of the drug, it is poorly absorbed sublingually or 

orally, and has no negative effects when used as directed.

1.1.3 Concomitant Conditions

Concomitant conditions are medical or psychiatric illnesses or conditions that occur simultaneously to the 

substance use disorder

1.1.4 Illicit Opioid Use

Illicit opioid use is the use of an illegal substance or the use of medication for reasons other than those in 

which the medication was intended or in higher doses than prescribed.

1.1.5 Induction

Induction is the initial phase of opioid treatment that may take place in the office setting or at home. 

Medication is adjusted until the beneficiary attains stabilization.

1.1.6 Maintenance Treatment

Maintenance treatment means the beneficiary has reached a stable, consistent schedule of medication and 

counseling that prevents the desire for opioid use while allowing for abstinence of illicit 

substances.

1.1.7 Medication Assisted Treatment

Medication Assisted Treatment (MAT) is the use of medications, in combination with counseling and 

behavioral therapies, to provide a whole-patient approach to the treatment of substance use 

disorders.

1.1.8 Office-based Opioid Treatment

Office-based Opioid Treatment (OBOT) is treatment of opioid use disorders in the clinical setting by a 

qualified provider as defined under Public Law 106-310 Section 3501(a)(G)(ii) to prescribe 

buprenorphine or buprenorphine- naloxone medications. Opioid use disorder is considered a 

chronic condition, and the management of this disorder is incorporated into the general care 

of the beneficiary.

1.1.9 Opioid Treatment Program (OTP)

An OTP is a treatment program federally certified by the Substance Abuse and Mental Health Services 

Administration (SAMHSA) according to 42 CFR § 8, to provide supervised assessment 

and medication assisted treatment for beneficiaries

who have an opioid use disorder diagnosis. OTPs require registration with the US Drug Enforcement Association (DEA) 

and licensure by the Division of Health Service Regulation (DHSR).

1.1.10 Opioid Withdrawal Syndrome

Opioid withdrawal syndrome is hyper-excitability caused by the absence of opioids. Symptoms of opioid 

withdrawal are drug cravings, anxiety, dysphoria, sweating, yawning, excessive tearing, 

rhinorrhea, insomnia, nausea, vomiting, diarrhea, cramps, muscle aches, and fever. 

Symptoms may appear within 8-12 hours with resolution after 7-10 days. Long acting drug 

withdrawal symptoms may appear within 1-3 days and may persist for days to weeks.

1.1.11 Qualified Provider

A physician, nurse practitioner, or physician assistant who has met the requirements and received a waiver 

under the Drug Addiction Treatment Act of 2000 (DATA 2000) to prescribe or dispense 

schedule III, IV, or V medications for the treatment of opioid addiction.

1.1.12 Stabilization

Stabilization is the lowest dose of buprenorphine or buprenorphine-naloxone at which the beneficiary 

discontinues the use of opioids without experiencing withdrawal symptoms, significant 

side effects, or uncontrollable cravings for the drug of use. The beneficiary is medically 

stable, fully-supported, able to perform activities of daily living, and substance free either 

with or without the assistance of medication.

2.0 Eligibility Requirements

2.1 Provisions

2.1.1 General

a) (The term “General” found throughout this policy applies to all Medicaid and 

NCHC policies)

a. An eligible beneficiary shall be enrolled in either:

1. The NC Medicaid Program (Medicaid is NC Medicaid program, unless 

context clearly indicates otherwise); or

2. The NC Health Choice (NCHC is NC Health Choice program, unless 

context clearly indicates otherwise) Program on the date of service 

and shall meet the criteria in Section 3.0 of this policy.

b. Provider(s) shall verify each Medicaid or NCHC beneficiary’s eligibility 

each time a service is rendered.

c. The Medicaid beneficiary may have service restrictions due to their 

eligibility category that would make them ineligible for this service.

d. Following is only one of the eligibility and other requirements for 

participation in the NCHC Program under GS 108A-70.21(a): Children must 

be between the ages of 6 through 18.

2.1.2 Specific

b) (The term “Specific” found throughout this policy only applies to this policy)

a. Medicaid

For office-based opioid treatment, an eligible Medicaid beneficiary who is a minor, 16 

through 17 years of age, shall have a documented history of at least two prior 

unsuccessful withdrawal management attempts.

Refer to NCGS § 90-21.5. Minor's consent sufficient for certain medical health 

services.

b. NCHC

For office-based opioid treatment, an eligible NCHC beneficiary who is a minor, 16 

through 17 years of age, shall have a documented history of at least two prior 

unsuccessful withdrawal management attempts. Refer to NCGS § 90-21.5. Minor's 

consent sufficient for certain medical health services.

2.2 Special Provisions

2.2.1 EPSDT Special Provision: Exception to Policy Limitations for a 

Medicaid Beneficiary under 21 Years of Age

a. 42 U.S.C. § 1396d(r) [1905(r) of the Social Security Act]

Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) is a federal 

Medicaid requirement that requires the state Medicaid agency to cover services, 

products, or procedures for Medicaid beneficiary under 21 years of age if the 

service is medically necessary health care to correct or ameliorate a defect, 

physical or mental illness, or a condition [health problem] identified through a 

screening examination (includes any evaluation by a physician or other licensed 

practitioner).

This means EPSDT covers most of the medical or remedial care a child needs to 

improve or maintain his or her health in the best condition possible, compensate for 

a health problem, prevent it from worsening, or prevent the development of 

additional health problems.

Medically necessary services will be provided in the most economic mode, as long 

as the treatment made available is similarly efficacious to the service requested by 

the beneficiary’s physician, therapist, or other licensed practitioner; the 

determination process does not delay the delivery of the needed service; and the 

determination does not limit the beneficiary’s right to a free choice of providers.

EPSDT does not require the state Medicaid agency to provide any service, 

product or procedure:

1. That is unsafe, ineffective, or experimental or investigational.

2. That is not medical in nature or not generally recognized as an 

accepted method of medical practice or treatment.

Service limitations on scope, amount, duration, frequency, location of service, and 

other specific criteria described in clinical coverage policies may be exceeded or 

may not apply as long as the provider’s documentation shows

that the requested service is medically necessary “to correct or ameliorate a defect, 

physical or mental illness, or a condition” [health problem]; that is, provider 

documentation shows how the service, product, or procedure meets all EPSDT 

criteria, including to correct or improve or maintain the beneficiary’s health in the 

best condition possible, compensate for a health problem, prevent it from worsening, 

or prevent the development of additional health problems.

b. EPSDT and Prior Approval Requirements

1. If the service, product, or procedure requires prior approval, the fact that 

the beneficiary is under 21 years of age does NOT eliminate the 

requirement for prior approval.

2. IMPORTANT ADDITIONAL INFORMATION about EPSDT and prior 

approval is found in the NCTracks Provider Claims and Billing 

Assistance Guide, and on the EPSDT provider page. The Web 

addresses are specified below.

NCTracks Provider Claims and Billing Assistance Guide: 

https://www.nctracks.nc.gov/content/public/providers/providermanuals.html

EPSDT provider page: http://dma.ncdhhs.gov/

2.2.1 EPSDT does not apply to NCHC beneficiaries

2.2.2 Health Choice Special Provision for a Health Choice Beneficiary age 6 

through 18 years of age

The Division of Medical Assistance (DMA) shall deny the claim for coverage for an 

NCHC beneficiary who does not meet the criteria within Section 3.0 of this policy. Only 

services included under the NCHC State Plan and the DMA clinical coverage policies, 

service definitions, or billing codes are covered for an NCHC beneficiary.

3.0 When the Procedure, Product, or Service Is Covered

c) Note: Refer to Subsection 2.2.1 regarding EPSDT Exception to Policy Limitations for 

a Medicaid Beneficiary under 21 Years of Age.

3.1 General Criteria Covered

Medicaid and NCHC shall cover the procedure, product, or service related to this policy when 

medically necessary, and:

a. the procedure, product, or service is individualized, specific, and consistent with 

symptoms or confirmed diagnosis of the illness or injury under treatment, and not in 

excess of the beneficiary’s needs;

b. the procedure, product, or service can be safely furnished, and no equally 

effective and more conservative or less costly treatment is available statewide;

and

c. The procedure, product, or service is furnished in a manner not primarily intended for 

the convenience of the beneficiary, the beneficiary’s caretaker, or the provider.

3.2 Specific Criteria Covered

3.2.1 Specific criteria covered by both Medicaid and NCHC

Medicaid and NCHC shall cover OBOT services for a beneficiary when all the 

following components are met: diagnosis and initial evaluation, initial laboratory testing, 

psychosocial treatment modalities, informed consent, treatment plan, treatment contract, 

and prescription drug monitoring.

a. Diagnosis and Initial Evaluation

A diagnosis of moderate or severe opioid use disorder supported by a 

comprehensive assessment signed and dated by the qualified provider completing 

the assessment is necessary. The assessment must address and document all of 

the following elements:

1. Screening for concomitant conditions that can necessitate a higher 

level of care or emergent care;

2. Substance use history consisting of the following: age of first use, 

substances used, change in effects over time, history of tolerance, 

history of overdose, history of withdrawal, attempts to quit, current legal 

issues due to drug use, and current problems with compulsivity or drug 

cravings;

3. Addiction treatment history consisting of the following: previous 

treatments for addiction, types of treatments tried, and outcomes 

of treatment;

4. Psychiatric history consisting of the following: diagnosis or diagnoses, 

psychiatric treatments recommended or tried, and outcomes of 

treatment attempts;

5. Family history consisting of the following: substance use disorders in the 

family, family medical history, and family psychiatric history;

6. Medical history consisting of the following: a detailed review of systems, 

past medical and surgical history, sexual history, likelihood of pregnancy 

for female beneficiaries, current and past medications, current 

medication (prescription and over the counter) doses, allergies, and pain 

history;

7. Social history consisting of the following: quality of recovery, family, 

and living environments, and substance use by other members of the 

support network;

8. Readiness for change consisting of the following: the beneficiary’s 

understanding of their substance use disorder, the beneficiary’s 

interest in treatment now, and whether treatment is voluntary or

coerced;

9. A complete physical examination focusing on physical findings related 

to addiction and any current signs of opioid intoxication, withdrawal, or 

overdose;

10. A mental status examination evaluating the following: general 

appearance, behavior and interaction, speech and voice, motor activity, 

mood and affect, perceptions or hallucinations, thought process and 

content, insight, judgement, motivation and readiness for change, 

beneficiary’s stated goals and expectations, cognitive function, 

personality, coping skills, and defense mechanisms. If the 

beneficiary’s psychiatric disorder is beyond the provider’s 

expertise andcomfort

level, referral to an addiction psychiatrist or psychologist for a 

full mental health evaluation or formal diagnosis is indicated 

prior to starting treatment;

11. The qualified provider shall document the benefits outweigh risks when 

prescribing buprenorphine and buprenorphine-naloxone combination 

product when the beneficiary is currently prescribed and taking 

antiretrovirals, hepatitis medication, benzodiazepines, sedatives, 

tranquilizers, antidepressants, or any other central nervous system 

depressant; and

12. The qualified provider shall document that office-based opioid treatment 

and the required counseling is an appropriate level of care for a 

beneficiary 16 through 17 years of age who meets eligibility 

requirements in Subsection 2.1.2.

*Note: Steps 1, 2, 3, 4, 5, 7, 8, and 10 may be performed by a 

physician extender or behavioral health professional trained in 

substance use disorders and signed off by the prescribing provider*

*Note: The 12 components (listed in subsection 3.2.1.a) of the comprehensive 

assessment are essential for the thorough care of a beneficiary with a 

substance use disorder diagnosis; however, completion of the full initial 

evaluation need not delay the initiation of treatment. Prompt treatment is a 

priority and completion of the 12 components over two or three visits is 

permissible at the discretion of the provider.

b. Initial Lab Testing

Initial laboratory testing is an important aspect of the initial evaluation and 

placement assessment. A urine pregnancy test must be performed on female 

beneficiaries of child bearing age unless known to be positive. Toxicology tests for 

drugs of abuse must be performed on all beneficiaries considered for OBOT services. 

Baseline labs consisting of serum electrolytes, blood urea nitrogen (BUN) and 

creatinine, complete blood count (CBC) with differential and platelet count, liver 

function tests, and lipid profile, may be collected during initial evaluation if deemed 

necessary by the OBOT provider to aide in determination of appropriateness for 

buprenorphine or buprenorphine- naloxone therapy. The following tests may be 

offered according to Centers for Disease Control (CDC) guidelines during the initial 

evaluation unless known to be positive:

1. Human Immunodeficiency Virus (HIV);

2. Hepatitis B and C;

3. Syphilis; and

4. Purified protein derivative (PPD)

c. Psychosocial Treatment Modalities

Evidence has demonstrated that greater success is achieved when combining 

medication assisted treatment with education and counseling for opioid dependence 

when compared to pharmacotherapy alone.

Medicaid and NCHC shall require a minimum of once monthly individual or group 

therapy sessions during the induction and stabilization phases of treatment 

conducted by a behavioral health professional licensed to treat substance use 

disorders and trained in the use of the American Society of Addiction Medicine 

(ASAM) Treatment Criteria for Addictive, Substance- Related, and Co-Occurring 

Conditions. Counseling sessions needed beyond induction and stabilization shall be 

at the discretion of the practitioner and beneficiary, based on the beneficiary’s 

ongoing needs and treatment goals.

The provider shall inquire whether the beneficiary is in counseling for their opioid 

use disorder and other co-occurring diagnoses, as applicable. If the beneficiary is not 

currently in counseling, the provider shall promptly refer the beneficiary to a 

licensed, North Carolina Local Management Entity- Managed Care Organization 

(MCO) enrolled, behavioral health professional. Optimally, counseling should begin 

within 48 hours of induction if urgent need is indicted.

Note: Urgent need for substance abuse counseling is defined as a condition in which 

the person is not imminently at risk of harm to self or others or unable to adequately 

care for self, but, by virtue of their substance use, is in need of prompt assistance to 

avoid further deterioration in the person’s condition which could require emergency 

assistance. The initial appointment for an urgent need must be within 48 hours.

If the beneficiary has already initiated counseling for substance use disorder, the 

qualified provider shall request ASAM placement recommendations from the 

behavioral health professional to ensure the beneficiary's needs do not exceed early 

intervention or outpatient service capability and document the results in the health 

record within ten (10) calendar days of induction.

If the beneficiary has not yet begun counseling for substance use disorder, the 

placement recommendations supplied by the behavioral health professional shall 

be documented in the health record within ten (10) calendar days of counseling 

initiation.

Alcoholics Anonymous (AA), Narcotics Anonymous (NA), Self- Management and 

Recovery Training (SMART) recovery and other self-help or guided recovery 

groups are not required by NC Medicaid or NCHC for continued service, however 

the OBOT provider can have additional requirements based on the beneficiary’s 

needs

If the beneficiary was identified by the behavioral health professional as requiring 

intensive outpatient services or higher, it does not preclude Office- based Opioid 

Treatment in addition to the higher level of care required.

Documentation must be placed in the health record that a referral has been made, 

where the beneficiary was referred to, and whether the beneficiary was accepted. If 

there is a delay in treatment at the appropriate level of care due to space availability, 

OBOT services may continue. The OBOT provider shall document in the health 

records that the beneficiary is awaiting an opening in the higher level of care and 

when placement availability is expected. This documentation must be updated 

weekly until the beneficiary is placed in the higher level of care or no longer requires 

advanced services.

Counseling attendance records signed by the behavioral health professional shall 

be obtained by the OBOT provider and placed in the health record.

d. Informed Consent

Before induction is initiated, the beneficiary shall be made aware of all treatment 

options available to them as well as the risks and benefits of office- based opioid 

treatment. Informed consent for office-based buprenorphine or buprenorphinenaloxone treatment must consist of all of the following information:

1. What buprenorphine or buprenorphine-naloxone is, how it works, how 

to administer, potential side effects, and signs of allergic reaction;

2. The importance of being in withdrawal for induction and consequences 

of not being in a state of withdrawal;

3. Buprenorphine or buprenorphine-naloxone maintains physical 

dependence and a sudden discontinuation may precipitate

withdrawal;

4. A description of induction, stabilization, maintenance, and tapering 

phases of treatment and expected or estimated timeframes for each 

phase;

5. Counseling requirements specific to this policy and any additional 

requirements as directed by the OBOT qualified provider;

6. Signs and symptoms of overdose and withdrawal due to 

inadequate dosing during the induction phase of treatment;

7. Possible interaction between buprenorphine or buprenorphinenaloxone and other prescription medications, such as HIV and hepatitis 

medications;

8. Risk of using buprenorphine or buprenorphine-naloxone while taking 

benzodiazepines, alcohol, or other central nervous system 

depressants. It must be noted that deaths have occurred when 

buprenorphine was taken concurrently with benzodiazepines;

9. Obstetrical risks for pregnant women with continued substance use. 

Risks to the pregnancy, mother, and fetus include preeclampsia, 

miscarriage, premature delivery, intrauterine growth restriction(IUGR), 

Neonatal Abstinence Syndrome (NAS) and fetal death; and

10. Any other information deemed necessary by the qualified provider.

e. Treatment Plan

A documented, individualized treatment plan must be kept in the beneficiary’s 

health record and updated as goals, beneficiary condition, expectations 

change. Topics to be addressed in the treatment plan are:

1. All current medications and doses;

2. Contact information for ancillary service providers for coordination of 

care;

3. Current medical and psychological diagnoses;

4. Short and long term goals with expected timeframes for meetinggoals;

5. Interventions or treatment modifications based on subjective 

and objective findings;

6. Contingency plan for non-compliance with treatment;

7. Signed release of information and notice of privacy practices; and

8. Any other information deemed necessary by the qualified provider.

f. Treatment Contract

Medicaid and NCHC shall delegate the decision to obtain a signed treatment 

contract to the qualified provider. If the provider elects to obtain a signed treatment 

contract, the following elements may be addressed in the treatment contract:

1. Agreement to keep all scheduled appointments;

2. Agreement to adhere to all office policies;

3. Agreement not to sell, share, or give any medications to another person;

4. Agreement to store medication in a secure location;

5. Understanding that mixing buprenorphine or buprenorphine-naloxone 

with benzodiazepines, alcohol, and other central nervous system 

depressants can lead to respiratory distress and deaths have been 

reported;

6. Agreement to take all medication as prescribed and to inform the OBOT 

provider when any medication is changed, discontinued, or prescribed 

by another provider;

7. Agreement to use an effective form of birth control during the entire 

course of treatment and to inform the OBOT provider immediately if 

pregnancy is suspected;

8. Timeframe in which to return to the office for urine drug screens and 

pill counts;

9. Specific stepwise consequences for unanticipated drug test results, 

sample tampering, diversion, lost or stolen medications, missed 

appointment, discrepancies between beneficiary supplied medication 

list and the North Carolina Controlled Substance Reporting System and 

any other violation of the treatment contract or non-compliance with the 

treatment plan;

10. An explanation of how requests for early refills or reports of lost, stolen, 

or damaged medication are handled; or

11. Any other information deemed necessary by the qualified provider.

g. Prescription Drug Monitoring

A check of the North Carolina Controlled Substance Reporting System (CSRS) 

must be performed and the results documented in the health record prior to 

beginning induction to ensure a beneficiary is not currently receiving 

buprenorphine or buprenorphine-naloxone from another provider. Any 

prescriptions found in this query, particularly opioids and benzodiazepines, must 

be confirmed with the beneficiary.

CSRS inquiries must also be conducted and documented with any buprenorphine 

or buprenorphine-naloxone dose change, any exceptions (signs or symptoms of 

withdrawal, reported loss of medication, unexpected result on urine drug test, 

admission of using illicit substances); or every six months at a minimum if the 

beneficiary is stable. If undisclosed prescriptions are discovered, patients shall be 

asked to sign a release of information (ROI) form allowing their treatment status to 

be communicated to the prescribers; signing the ROI is requisite for remaining in 

treatment.

3.2.2 Phases of Treatment

3.2.2.1 Induction

Induction usually takes place over the course of one (1) week either at home 

or in the office setting. Office visits may be as frequently as daily or 

infrequently as weekly based on clinical findings and the needs of the 

beneficiary. The goal of induction is to find the lowest dose of buprenorphine 

or buprenorphine-naloxone combination at which the beneficiary discontinues 

use of other opioids and experiences no withdrawal symptoms, minimal or no 

side effects, and no uncontrollable cravings for drugs of abuse. Induction 

protocol will depend on the opioids of abuse and whether the beneficiary is in 

a state of withdrawal at time of induction.

3.2.2.2 Stabilization

Stabilization usually takes place over the course of one to three months with 

office visits being weekly or bi-weekly until full stabilization has occurred as 

evidenced by stable buprenorphine or buprenorphine- naloxone dose, no 

reported cravings or withdrawal, and urine drug screen is negative for opioids 

and positive for buprenorphine or buprenorphine-naloxone.

3.2.2.3 Maintenance

The beneficiary is opioid free without signs of withdrawal, no increase in 

buprenorphine or buprenorphine-naloxone has been required, there have been 

no irregularities with urine drug screens or drug registry inquiries, and the 

beneficiary is making progress towards or meeting desired goals. Once 

maintenance stage has been achieved, visits may be as frequent as once (1) 

monthly if deemed necessary by the qualified provider. Maintenance 

treatment may continue as long as the beneficiary meets the continued service 

criteria in Subsection 3.2.4 or they meet discharge criteria in Subsection 

3.2.5 and the tapering process begins. Extenuating circumstance may arise 

that necessitate

visits more frequently that once per month and medical justification for more 

frequent visits must be documented in the beneficiary’s health record.

3.2.3 Urine Drug Screens

Presumptive urine drug testing (UDT) may be ordered by the qualified provider caring 

for a beneficiary when it is necessary to rapidly obtain or integrate results into clinical 

assessment and treatment decisions.

Definitive UDT may be ordered by the qualified provider caring for a beneficiary 

when it is necessary to confirm any one of the following when making clinical 

treatment decisions:

a. Identify a specific substance or metabolite that is inadequately detected by 

a presumptive UDT;

b. Definitively identify specific drugs in a large family of drugs;

c. Identify a specific substance or metabolite that is not detected by 

presumptive UDT such as fentanyl, meperidine, synthetic cannabinoids 

and other synthetic or analog drugs;

d. Identify drugs when a definitive concentration of a drug is needed to guide 

management

e. Identify a negative, or confirm a positive, presumptive UDT result that is 

inconsistent with a beneficiary’s self-report, presentation, medical history, 

or current prescribed pain medication plan;

f. Rule out an error as the cause of a presumptive UDT result;

g. Identify non-prescribed medication or illicit use for ongoing safe 

prescribing of controlled substances; or

h. Use in a differential assessment of medication efficacy, side effects, 

or drug-drug interactions.

The clinician’s rationale for the presumptive and definitive UDT and the 

tests ordered must be documented in the patient’s medical record.

3.2.4 Continued Service Criteria

The beneficiary shall meet the following criteria for continued service:

a. The beneficiary is attending office visits and counseling as required, 

but the desired outcome or level of functioning has not been 

restored, improved, or sustained over the timeframe outlined in the 

beneficiary’s treatment plan; or

b. The beneficiary has attended office visits and counseling as 

required, has achieved current treatment plan goals, and additional 

goals are indicated as evidenced by documented symptoms.

3.2.5 Discharge Criteria

Any ONE of the following criteria must be met:

a. The beneficiary or legally responsible person no longer wishes to 

receive these services; or

b. The beneficiary, based on presentation and failure to show 

improvement, despite modifications in the treatment plan, requires 

a more appropriate level of care; or

c. The beneficiary has achieved current treatment plan goals and

the desired outcome or level of functioning has been restored, 

improved, or sustained over the timeframe outlined in the 

beneficiary’s treatment plan.

3.2.6 Telemedicine

Telemedicine and telepsychiatry services may be used for the medical 

or counseling portions of OBOT services providing they are in 

accordance with DMA policy 1H, Telemedicine and Telepsychiatry. If 

telemedicine is utilized for the medical management portion of OBOT 

services, the beneficiary shall be located at a facility where a physical 

exam can be conducted by a nurse practitioner, physician assistant, or 

MD at the time of the telemedicine visit.

3.2.7 Medicaid Additional Criteria Covered

In addition to the specific criteria covered in Section 3.2 of this policy, 

Medicaid shall cover OBOT when the following criteria are met for the 

following special populations:

a. Pregnant Women: If it is determined by the OBOT provider that a 

higher level of care is not required and the beneficiary meets criteria 

for Office-based Opioid Therapy in subsection 3.2, the beneficiary 

shall be referred for prenatal care, encouraged to remain in a 

substance use treatment program, and be considered for a licensed 

Opioid Treatment Program if office-based treatment compliance 

cannot be guaranteed.

Note: Providers shall refer pregnant beneficiaries to another provider if they 

do not have the skill set or comfort level to care for a pregnant beneficiary 

with a substance use disorder

b. Women of Childbearing Age: Shall be encouraged to use 

effective birth control methods and referred for family planning 

services. In the event of pregnancy, the beneficiary shall inform the 

qualified provider immediately as a change in the treatment plan 

and medication may be required if the beneficiary is currently taking 

buprenorphine combined with naloxone.

c. Breastfeeding mothers: shall be encouraged to remain in OBOT 

services for the duration of their breastfeeding. Buprenorphine 

metabolite levels secreted in breastmilk is thought to be low. 

Mothers with HIV, or with active alcohol, cocaine, oramphetamine 

substance use require special consideration when encouraging 

breastfeeding.

3.2.8 NCHC Additional Criteria Covered

In addition to the specific criteria covered in Section 3.2. of this policy, 

NCHC shall cover OBOT when the following criteria are met for the 

following special populations:

a. Women of Childbearing Age: Shall be encouraged to use effective birth 

control methods and referred for family planning services. In the event of 

pregnancy, the beneficiary shall inform the qualified provider immediately 

as a change in the treatment plan and medication will be required.

4.0 When the Procedure, Product, or Service Is Not Covered

d) Note: Refer to Subsection 2.2.1 regarding EPSDT Exception to Policy Limitations for 

a Medicaid Beneficiary under 21 Years of Age.

4.1 General Criteria Not Covered

Medicaid and NCHC shall not cover the procedure, product, or service related to this policy 

when:

a. the beneficiary does not meet the eligibility requirements listed in Section 2.0;

b. the beneficiary does not meet the criteria listed in Section 3.0;

c. the procedure, product, or service duplicates another provider’s procedure, 

product, or service; or

d. The procedure, product, or service is experimental, investigational, or part of a 

clinical trial.

4.2 Specific Criteria Not Covered

4.2.1 Specific Criteria Not Covered by both Medicaid and NCHC

Medicaid and NCHC shall not cover Office-based Opioid Treatment services when:

a. A diagnosis of substance use disorder for opioids cannot be made or 

supported by assessment or documentation;

b. The provider has not complied with the requirements and limitations in

Sections 5.0, 7.0, and subsection and 3.2;

c. Initial diagnosis and evaluation, or prescribing of buprenorphine or 

buprenorphine-naloxone by physicians, nurse practitioners, physician 

assistants, and locum tenens physicians without a DATA 2000 waiver;or

d. The beneficiary no longer meets the requirements in Subsection 3.2.4.

4.2.2 Medicaid Additional Criteria Not Covered

Medicaid shall not cover medical office visits beyond the annual legislative limit for 

mandatory services for any the following circumstances:

a. The signed treatment contract is violated without a documented intervention 

by the provider;

b. Buprenorphine or buprenorphine-naloxone is not detected by qualitative or 

quantitative testing on more than two occasions in a consecutive 90 

calendar day period without a documented medical cause; or

c. Failure of the provider to make and document changes to the treatment plan 

based on subjective or objective data that suggests a medication dose 

change or other change in treatment is required as evidenced by signs or

symptoms

of withdrawal, ongoing use of illicit substances, missed appointments, or 

evidence of diversion.

4.2.3 NCHC Additional Criteria Not Covered

NCGS § 108A-70.21(b) “Except as otherwise provided for eligibility, fees, 

deductibles, copayments, and other cost sharing charges, health benefits coverage 

provided to children eligible under the Program shall be equivalent to coverage 

provided for dependents under North Carolina Medicaid Program except for the 

following:

a. No services for long-term care.

b. No nonemergency medical transportation.

c. No EPSDT.

d. Dental services shall be provided on a restricted basis in accordance 

with criteria adopted by the Department to implement this subsection.”

5.0 Requirements for and Limitations on Coverage

e) Note: Refer to Subsection 2.2.1 regarding EPSDT Exception to Policy 

Limitations for a Medicaid Beneficiary under 21 Years of Age.

5.1 Prior Approval

a. Medicaid and NCHC shall not require prior approval for initiation of Office-based Opioid 

Treatment services.

b. Medicaid and NCHC shall require prior approval for office visits for Office-based Opioid 

Treatment services that are in excess of the annual legislated limit for mandatory 

services.

5.2 Prior Approval Requirements

5.2.1 General

The provider(s) shall submit to the Department of Health and Human Services 

(DHHS) Utilization Review Contractor the following:

a. the prior approval request; and

b. All health records and any other records that support the beneficiary has 

met the specific criteria in Subsection 3.2 of this policy.

5.2.2 Specific

For continued OBOT services beyond the annual legislative limit for mandatory 

services, the OBOT provider shall submit all of the following:

a. current treatment plan;

b. signed treatment contract (if one was obtained);

c. behavioral health attendance records (if beneficiary is attendingcounseling);

d. any disciplinary contracts signed by the beneficiary and provider;

e. last five encounter notes (or initial evaluation through current if the 

beneficiary has not had five visits); and

f. last ten urine drug screens (both presumptive and definitive) by date 

of service

5.3 Additional Limitations or Requirements

None Apply.

6.0 Provider(s) Eligible to Bill for the Procedure, Product, orService

To be eligible to bill for the procedure, product, or service related to this policy, the provider(s) shall:

a. meet Medicaid or NCHC qualifications for participation and be enrolled as a North 

Carolina Medicaid provider;

b. have a current and signed Department of Health and Human Services (DHHS) 

Provider Administrative Participation Agreement; and

c. Bill only for procedures, products, and services that are within the scope of their clinical 

practice, as defined by the appropriate licensing entity.

6.1 Provider Qualifications and Occupational Licensing Entity Regulations

Qualified providers shall complete the required specialized training, and shall be granted the 

waiver authority from the Substance Abuse and Mental Health Services Administration 

(SAMHSA) to prescribe and dispense buprenorphine or buprenorphine- naloxone in an officebased practice. In addition to the DATA 2000 waiver, both DEA and North Carolina Division of 

Mental Health, Developmental Disabilities and Substance Abuse Services Drug Control Unit 

registrations are required to operate as an Office-based Opioid Treatment Practice. Providers 

working in licensed Opioid Treatment Programs (OTPs) shall dispense buprenorphine or 

buprenorphine-naloxone following the federal and state OTP rules and policies. Nurses working in 

licensed Opioid Treatment Programs (OTPs) shall administer buprenorphine or buprenorphinenaloxone following the federal and state OTP rules and policies.

Providers who utilize Buprenorphine or buprenorphine-naloxone in Office-based Opioid 

Treatment (OBOT) shall be able to recognize opioid use disorders and be knowledgeable about 

the appropriate use of opioid agonist, antagonist, and partial agonist medications. Providers shall 

demonstrate required qualifications according to DATA 2000 and obtain a waiver from the 

Substance Abuse and Mental Health Services Administration (SAMHSA).

Providers of counseling and other therapeutic services to a beneficiary in an Office-based Opioid 

Treatment program shall be licensed to provide those services and directly enrolled with North 

Carolina Division of Medical Assistance or the appropriate LME- MCO. Licensed professionals 

providing outpatient treatment services to a beneficiary in an Office-based Opioid Treatment 

program shall follow the outpatient Clinical Coverage Policy 8C, Outpatient Behavioral Health 

Services Provided by Direct-Enrolled Providers, located on DMA’s website at 

http://dma.ncdhhs.gov/.

6.2 Provider Certifications

6.2.1 SAMHSA Waiver

The Drug Enforcement Administration (DEA) issues a special identification number for 

providers who have been granted the waiver from the Substance Abuse

and Mental Health Services Administration (SAMHSA) to prescribe and dispense 

buprenorphine or buprenorphine-naloxone. Providers who provide this service are required 

to have the SAMHSA waiver and the special DEA number.

7.0 Additional Requirements

f) Note: Refer to Subsection 2.2.1 regarding EPSDT Exception to Policy 

Limitations for a Medicaid Beneficiary under 21 Years of Age.

7.1 Compliance

Provider(s) shall comply with the following in effect at the time the service is rendered:

a. All applicable agreements, federal, state and local laws and regulations including 

the Health Insurance Portability and Accountability Act (HIPAA) and record retention 

requirements; and

b. All DMA’s clinical coverage policies, guidelines, policies, provider manuals, 

implementation updates, and bulletins published by the Centers for Medicare 

and Medicaid Services (CMS), DHHS, DHHS division(s) or fiscal contractor(s).

In addition to the above, the provider shall comply with the following:

a. Policies of the North Carolina Medical Board; and

b. Center for Substance Abuse Treatment. Clinical Guidelines for the Use of 

Buprenorphine in the Treatment of Opioid Addiction. Treatment Improvement 

Protocol (TIP) Series 40. DHHS Publication No. (SMA) 04-3939. Rockville, MD: 

Substance Abuse and Mental Health Services Administration, 2004.

7.2 Documentation

7.2.1 Health Record Documentation

Provider(s) shall document and maintain, in each beneficiary’s health record, at a 

minimum, the following:

a. Demographic information: the beneficiary’s full name, contact information, 

date of birth, race, gender, and admission date;

b. The beneficiary’s name and date of birth must be on each page generated 

by the office;

c. The health record number of the beneficiary must be on each page 

generated by the office;

d. The Beneficiary’s Identification Number for services must be on all 

contracts, progress note pages, billing records, and other documents or

forms that have a place for it;

e. An individualized treatment plan and treatment contract;

f. Initial diagnosis and any tools used during the initial evaluation period;

g. Signed and dated copies of any testing, consultations, encounter notes, 

and reports; and

h. Communication regarding coordination of care activities; and

7.2.2 Encounter Notes

There must be a note documenting the following information for each encounter. Notes 

may be handwritten if legible, otherwise they must be dictated or in electronic health 

record (EHR), reviewed, and signed within three business days of the encounter. Prefilled electronic health records must be reviewed for accuracy prior to being 

electronically signed. All notes must be dated and the provider shall sign all documents 

with their name and credentials.

Encounter documents must contain the following elements at a minimum:

a. Date of service;

b. Subjective response to treatment;

c. Review of Systems(ROS) which may be carried over on electronic charting 

or documented in the handwritten or dictated note;

d. Documentation of physical examination and possible signs of withdrawal or 

intoxication;

e. Medication list, including new and changed prescriptions, updated at 

each visit;

f. Results of periodic tests and interventions such as urine drug screens, pill 

counts, CSRS inquiries, and actions taken for unanticipated lab results or 

missed appointments;

g. Any consults made with other providers (mental health, OB/GYN, PCP, etc.) 

or family members of the beneficiary; and

h. Follow up plans.

Note: There needs to be clear documentation when a beneficiary cancels, they no show 

or reschedules encounters. If there is any gap in services, there needs to be an 

explanation in the health record about what the issue is. If the client has attendance 

problems, that needs to be addressed with the client, and documented in the health record 

with an explanation for the missed appointments.

Note: When an electronic signature is entered into the electronic record by agency 

staff (employees or authorized individuals under contract with the agency), the 

standards for Electronic Signatures found in the September 2011 Medicaid Bulletin 

(http://dma.ncdhhs.gov/document/archived-medicaid- bulletins-2010-2013) must be 

followed. In addition, electronic signatures must comply with federal guidelines 

found in 45 CFR parts 160 and 162.

8.0 Policy Implementation and History

Original Effective Date: Month Day, Year

History:

Date Section or

Subsection 

Amended

Change

02/01/2017 All Sections and 

Attachment(s)

New policy on Buprenorphine or buprenorphine-naloxone 

Treatment Services.

02/21/2017 Attachment A (C) Typographical error fixed; 99213 changed to 99203 on first line of 

CPT Codes.

03/15/2017 Subsection 3.2.1 (c) Clarified counseling requirements as follows:

Medicaid and NCHC shall require a minimum of once monthly 

individual or group therapy sessions during the induction and 

stabilization phases of treatment conducted by a behavioral health 

professional licensed to treat substance use disorders and trained in the 

use of the American Society of Addiction Medicine (ASAM) 

Treatment Criteria for Addictive, Substance- Related, and CoOccurring Conditions. Counseling sessions needed beyond induction 

and stabilization shall be at the discretion of the practitioner and 

beneficiary, based on the beneficiary’s ongoing needs and treatment 

goals.

The provider shall confirm the beneficiary is in counseling for their 

opioid use disorder and other co-occurring diagnoses, as applicable. If 

the beneficiary is not currently in counseling, the provider shall 

promptly refer the beneficiary to a licensed, North Carolina Local 

Management Entity-Managed Care Organization (MCO) enrolled, 

behavioral health professional. Optimally, counseling should begin 

within 48 hours of induction if urgent need is indicted.

03/15/2017 Subsection 5.2.2 (c) Added “if beneficiary is attending counseling”

08/01/2017 Subsection 3.2.1 (a) Added clarifying statement:

**Note: The 12 components (listed in subsection 3.2.1.a) of the 

comprehensive assessment are essential for the thorough care of a 

beneficiary with a substance use disorder diagnosis; however, 

completion of the full initial evaluation need not delay the 

initiation of treatment. Prompt treatment is a priority and 

completion of the 12 components over two

or three visits is permissible at the discretion of the provider.

Date Section or 

Subsection

Amended

Change

08/01/2017 Subsection 3.2.1 (c) Clarified counseling requirements as follows:

The provider shall inquire whether the beneficiary is in counseling for 

their opioid use disorder and other co-occurring diagnoses, as 

applicable. If the beneficiary is not currently in counseling, the 

provider shall promptly refer the beneficiary to a licensed, North 

Carolina Local Management Entity-Managed Care Organization 

(MCO) enrolled, behavioral health professional. Optimally, counseling 

should begin within 48 hours of induction if urgent need is indicted.

01/01/2018 Subsection 5.1 (b) Removed the following:

Medicaid and NCHC shall require Pharmacy Prior Authorization for 

use of buprenorphine or buprenorphine-naloxone combination 

medication (refer to pharmacy prior approval and

renewal criteria located at https://www.nctracks.nc.gov/)

Attachment A: Claims-Related Information

Provider(s) shall comply with the, NCTracks Provider Claims and Billing Assistance Guide, Medicaid bulletins, 

fee schedules, DMA’s clinical coverage policies and any other relevant documents for specific coverage and 

reimbursement for Medicaid and NCHC:

A. Claim Type

Professional (CMS-1500/837P transaction)

B. International Classification of Diseases, Tenth Revision (ICD-10) and Procedures

Provider(s) shall report the ICD-10 and procedures code(s) to the highest level of specificity that supports 

medical necessity. Provider(s) shall use the current ICD-10 edition and any subsequent editions in effect 

at the time of service. Provider(s) shall refer to the applicable edition for code description, as it is no 

longer documented in the policy.

C. Code(s)

Provider(s) shall report the most specific billing code that accurately and completely describes the 

procedure, product or service provided. Provider(s) shall use the Current Procedural Terminology (CPT), 

Health Care Procedure Coding System (HCPCS), and UB-04 Data Specifications Manual (for a complete 

listing of valid revenue codes) and any subsequent editions in effect at the time of service. Provider(s) shall 

refer to the applicable edition for the code description, as it is no longer documented in the policy.

If no such specific CPT or HCPCS code exists, then the provider(s) shall report the procedure, product 

or service using the appropriate unlisted procedure or service code.

CPT Code(s)

99201 99202 99203 99204

99205 99211 99212 99213

99214 99215 99241 99242

99243 99244 99245 T1015

Unlisted Procedure or Service

CPT: The provider(s) shall refer to and comply with the Instructions for Use of the CPT Codebook, Unlisted 

Procedure or Service, and Special Report as documented in the current CPT in effect at the time of service.

HCPCS: The provider(s) shall refer to and comply with the Instructions For Use of HCPCS National 

Level II codes, Unlisted Procedure or Service and Special Report as documented in the current HCPCS 

edition in effect at the time of service.

D. Modifiers

Provider(s) shall follow applicable modifier guidelines.

E. Billing Units

Provider(s) shall report the appropriate code(s) used which determines the billing unit(s).

F. Place of Service

Office, clinics, and Federally Qualified Health Centers

G. Co-payments

For Medicaid refer to Medicaid State Plan, Attachment 4.18-A, page 1, located at 

http://dma.ncdhhs.gov/.

For NCHC refer to G.S. 108A-70.21(d),

H. Reimbursement

Provider(s) shall bill their usual and customary charges. For a 

schedule of rates, refer to: http://dma.ncdhhs.gov

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