OTP Weekly Bundled Billing: How G2067–G2075 Actually Work

What Counts as One Episode of Care

A Medicare OTP episode of care is a period of seven contiguous days, billed as one bundled payment. The bundle represents everything the program furnishes during that week: the medication itself, dosing and administration, substance use counseling, individual and group therapy, and toxicology testing. None of those services is billed separately on a standard episode.

The CMS OTP Billing & Payment guidance sets two rules that control every claim. First, the same weekly bundle must not be reported more than once for the same seven-day period. Second, at least one qualifying service — from either the drug component or the non-drug component — must be furnished during the week represented by the claim. A week in which the patient received nothing is not billable, even if the patient remains enrolled in the program.

The Base Bundle Codes

The base bundle is selected by medication and formulation, not by the services delivered that week. A methadone patient and an oral buprenorphine patient who receive identical counseling in the same week are still billed under two different G-codes, because the medication drives the bundle.

These bundles apply only inside a Medicare-enrolled OTP. Office-based practices prescribing buprenorphine follow a completely different path built on standard E/M codes — explained in our guide to office-based buprenorphine billing after the X-waiver . And practices administering injectable naltrexone outside the OTP bundle bill the drug and administration separately — see the Vivitrol J2315 buy-and-bill walkthrough for that workflow.

Billing a Mid-Week Treatment Start

According to CMS, an OTP can run its weekly billing cycle two ways: a standard cycle that starts every episode on the same day of the week, or patient-specific cycles anchored to each patient’s first day of treatment. Under the standard-cycle approach, the date of service is the first day of the OTP’s billing week; under the patient-anchored approach, an episode that begins on a Wednesday runs through the following Tuesday, and the next episode starts the following Wednesday. Neither approach requires episodes to align to calendar weeks.

A mid-week treatment start is billable under either approach. On a standard cycle, CMS permits billing the applicable code for the partial week if the threshold — at least one qualifying service — is met, and allows modifier 59 with documentation in the limited situations where a bundle must be billed more than once in a seven-day period, such as syncing a new patient to the OTP’s standard cycle or holiday weeks when the program is partially closed. On patient-anchored cycles, per CMS, the date of service for each subsequent consecutive episode is simply the first day after the previous seven-day period ends.

Whichever approach the program uses, it has to be one approach. The classic overlap error happens when the billing system defaults to calendar weeks while the clinical record anchors to admission dates — two conventions producing claims whose date spans eventually collide, and overlapping episodes are a rejection trigger.

1. Pick one cycle convention — standard weekly or patient-anchored — and configure both the clinical record and the billing system to it.
2. Sequence episodes in back-to-back seven-day blocks with no gaps and no overlaps in the reported date spans, and append modifier 59 with documentation only in the limited sync situations CMS describes.
3. Re-anchor only when care re-starts after a true break in treatment — a missed week with no qualifying service is simply not billed, and per CMS the date of service on restart is the first day the patient is seen again.

One more layer sits on top of the Medicare rules: some state Medicaid programs require program-specific modifiers on MOUD claims. Our guide to modifier HF vs. HE in MOUD billing explains how those state-level rules work and how to verify your state’s requirements.

Drug Component vs. Non-Drug Component

Every OTP bundle is built from two components: the drug component (the medication) and the non-drug component (everything else). The non-drug component covers dosing and administration, substance use counseling, individual and group therapy, toxicology testing, intake activities, and periodic assessments.

The split matters for one practical reason: a week without medication can still be billable. When a patient receives counseling or therapy during a week in which no medication is furnished — for example, during a supervised taper or a temporary medication hold — the program reports the weekly non-drug bundle, G2074, rather than skipping the week or forcing a medication bundle the record does not support.

Beyond the base bundles, CMS guidance includes separate add-on codes for services that exceed the standard bundle: G2076 for intake, G2077 for periodic assessment, G2078–G2079 for qualifying take-home medication supplies, and G2080 for counseling that substantially exceeds the amount specified in the patient’s plan of care. Each add-on must reflect documented work — add-ons attached by habit rather than by documentation are a review trigger.

Several of these services — intake, periodic assessment, and counseling — can also be furnished remotely under specific conditions, including an audio-only exception when video technology isn’t available to the patient. Our guide to telehealth billing for buprenorphine and methadone treatment covers when those rules apply and how they differ from standard telehealth billing.

Common OTP Billing Mistakes

Most OTP claim problems trace to a handful of repeatable workflow errors. Each one is preventable with a pre-bill check that validates the episode span, the medication pathway, and the documentation behind every add-on.

For the complete picture of why addiction treatment claims fail — including ASAM documentation gaps, prior authorization lapses, and 42 CFR Part 2 conflicts that reach far beyond OTP bundles — see our full guide to why SUD and MOUD claims get denied and how to appeal them .

Programs seeing repeated rejections, suspended claims, or underpaid episodes can use ClaraRCM’s denial management services and accounts receivable follow-up to work the backlog while the pre-bill workflow is corrected. A billing audit and cleanup of past episodes frequently recovers non-drug weeks that were never billed at all.

Frequently Asked Questions About OTP Bundled Billing