Telehealth Billing for Buprenorphine and Methadone Treatment in 2026

Audio-Video vs. Audio-Only Billing Rules

The service determines the code; the technology determines the modifier. Under the CMS OTP Billing & Payment guidance , OTPs use place of service 58 on every telehealth claim and report one of three telecommunications add-on codes with the correct modifier to signal how the visit was delivered.

According to CMS, for OTP telecommunications claims with dates of service on or after May 12, 2023, the modifier layer is unchanged in 2026:

• Modifier 95 when the service was furnished using audio-video technology.
• Modifier 93 or modifier FQ when the service was furnished using audio-only technology — documenting that video wasn’t available or the patient didn’t consent.

The service-side codes track a specific decision. G2076 covers the OTP intake add-on. Under the CY 2025 Physician Fee Schedule final rule, CMS made permanent an OTP’s ability to bill G2076 via two-way audio-video for methadone initiation when the program can adequately evaluate the patient over that platform, provided SAMHSA and DEA authorize the underlying prescribing at the time of service. G2077 covers periodic assessments, and audio-only billing for those assessments became permanent beginning January 1, 2025 when video isn’t available and other SAMHSA and DEA requirements are met. G2080 covers additional counseling or therapy beyond the weekly bundle, and can be furnished via either audio-video or audio-only, with the modifier reflecting the mode.

When the Audio-Only Exception Applies

Audio-only telehealth in OTP billing is not a fallback for provider convenience — it is a documented exception with specific conditions the record must support. Per CMS OTP billing guidance and the CY 2025 PFS final rule, an audio-only visit is billable when the patient does not have access to two-way audio-visual communication technology, or does not consent to its use, and all other applicable OTP requirements are met at the time of the service. Documenting the patient-side reason is what makes the modifier 93 or FQ claim defensible on review.

A separate layer sits behind this: DEA and SAMHSA control what an OTP or telehealth prescriber may do remotely with the underlying controlled medication. On January 17, 2025, DEA and HHS finalized the buprenorphine telemedicine prescribing rule , which took effect February 18, 2025 and made permanent the ability to initiate buprenorphine treatment via audio-video or audio-only telemedicine and prescribe up to a six-month initial supply, provided the prescriber first checks the state prescription drug monitoring program. Separately, DEA extended broader controlled-substances telemedicine flexibilities through December 31, 2026 while it finalizes the permanent special-registration framework, so audio-only initiation of buprenorphine for OUD continues to be permitted under federal law through that date.

For office-based buprenorphine practices that also use telehealth — billing standard E/M rather than OTP add-ons — the billing pathway is different from the OTP add-on codes covered here. That workflow is covered in our guide to office-based buprenorphine billing after the X-waiver . Practices with a broader telehealth caseload can also review ClaraRCM’s telehealth billing services for cross-specialty support.

How OTP Telehealth Differs From Standard Medicare Telehealth

OTP telehealth runs on its own billing layer: dedicated G-codes, place of service 58, and telecommunications add-on codes that sit beside the weekly bundled episode — not the standard physician telehealth machinery. That distinction matters at the claim level, because using the wrong set of codes or modifiers gets the visit denied even when the care itself was appropriate.

Three practical differences catch billers first. First, the place of service: OTP telehealth uses POS 58 on the OTP’s claim, whereas general Medicare telehealth uses POS 02 (originating site other than home) or POS 10 (patient at home). Second, the code family: the OTP’s telecommunications add-ons — G2076, G2077, G2080 — are OTP-specific and do not exist on a standard physician telehealth claim. Third, the interaction with the weekly bundle: OTP telehealth services attach to the underlying seven-day episode covered in our guide to OTP weekly bundled billing , so overlapping episode spans or duplicate add-ons still cause the same rejections telehealth was supposed to prevent.

One more layer sits on top nationally: some state Medicaid programs require program-specific modifiers on MOUD claims regardless of whether the service is in-person or telehealth. Our guide to modifier HF vs. HE in MOUD billing explains how those state rules interact with federal telehealth billing.

Frequently Asked Questions