Substance Use Disorder Billing: SBIRT, OTP Bundles and Consent
Substance use disorder billing is the set of coding and claim rules for screening, brief intervention, medication treatment and counseling for people with a substance use disorder (SUD). Medicare uses different routes for office-based care, SBIRT and opioid treatment programs. This guide shows psychotherapists and psychiatrists the codes, the bundles and the privacy rules that change how a claim is built.
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Last reviewed: 10/10/26. Sources are listed at the bottom of this page.
What substance use disorder billing covers
Substance use disorder billing spans office visits, screening codes and bundled program payments.
The right route depends on who you are and where care happens. A psychiatrist who prescribes in the office reports E/M visits and any add-on codes. A therapist who screens a patient uses SBIRT codes where the payer allows them. An opioid treatment program (OTP) bills weekly bundles. Each path in substance use disorder billing has its own rules, and mixing them is the fastest way to a denial.
The Medicare facts here come from the CMS Medicare mental health booklet (MLN1986542, March 2026), the CMS SBIRT fact sheet (May 2025) and CMS Transmittal 13572 (March 3, 2026), all checked 10/10/26.
Practices often add SUD services one at a time, and that is where claims go wrong. Our practice management guides cover the business side, and the who we serve page lists the practice types MCM South works with. MCM South works claims like these every week for psychotherapists and psychiatrists.
What is substance use disorder billing in plain terms?
Substance use disorder billing is how a practice reports screening, intervention, medication and counseling for SUD to a payer. In Medicare, that can mean SBIRT codes for screening and brief intervention, office-based opioid use disorder (OUD) codes G2086, G2087 and G2088, or an OTP weekly bundle. Substance use disorder billing also includes the privacy rules that govern SUD records.
SBIRT codes in substance use disorder billing
SBIRT stands for screening, brief intervention and referral to treatment.
Medicare lists three SBIRT-related codes for alcohol or non-tobacco substance misuse. Time decides which one you report, and your record must show start and stop times or total face-to-face time.
| Code | What it reports | Time |
|---|---|---|
| G2011 | Shorter same-day SBIRT service for alcohol or substance misuse (listed in the CMS booklet) | 5 to 14 minutes |
| G0396 | Structured assessment (for example AUDIT or DAST) plus a brief intervention | 15 to 30 minutes |
| G0397 | Structured assessment plus an intervention | More than 30 minutes |
The CMS SBIRT fact sheet lists these practitioners as Medicare-eligible: physicians, physician assistants, nurse practitioners, clinical nurse specialists, clinical psychologists, clinical social workers, certified nurse midwives, independently practicing psychologists, marriage and family therapists and mental health counselors. It does not list 99408 or 99409, so do not assume they apply to Medicare. Some commercial plans and state Medicaid programs choose their own SBIRT codes.
Medicare also covers alcohol misuse screening and counseling for patients who misuse alcohol but are not dependent, with up to four brief face-to-face sessions per year (CMS booklet). Use the CPT code guide to check how these codes sit next to your usual psychotherapy codes.
OTP weekly bundles and medication treatment
Opioid treatment programs are paid by the week, not by the visit.
Under CMS Transmittal 13572, an episode of care is a contiguous 7-day period, and at least one OUD treatment service must be furnished in the week. Only an entity enrolled with Medicare as an OTP can bill the codes below. OTPs may not bill other codes, such as those paid under the Physician Fee Schedule.
| Code | What it reports | Note |
|---|---|---|
| G2067 | Methadone, weekly bundle | Drug and non-drug parts in one payment |
| G2068 | Oral buprenorphine, weekly bundle | Same structure |
| G2069 / G0533 | Injectable buprenorphine, monthly / weekly bundle | Includes the injection |
| G2073 | Naltrexone, weekly bundle | Includes the injection |
| G2074 | Weekly bundle with no drug | For weeks without medication, such as monthly injectables |
| G2076 to G2080 | Add-ons: intake, periodic assessment, take-home supplies, extra counseling | Listed separately |
| G0137 | Intensive outpatient services | At least nine services over 7 days |
Claims for OTP G codes carry place of service 58 (non-residential opioid treatment facility). Counseling or therapy furnished by telecommunication is not billed separately by the practitioner, since the bundle already pays for it. Intensive outpatient services under G0137 delivered by audio-video or audio-only technology are not payable under Part B. Our reimbursement terms explain bundled payments.
Substance use disorder billing in an OTP setting is mostly a question of enrollment and bundle selection. If you are a prescriber or counselor outside an OTP, you do not bill these codes. Coordinate with the OTP so the same service is not paid twice. Medicare's IOP benefit also covers SUD, and OTPs may furnish it (CMS Transmittal 12425).
Medicare, Medicaid and private rules for substance use disorder billing
Keep the three rule sets apart.
Medicare
Medicare pays SBIRT under the Physician Fee Schedule and the hospital outpatient payment system, pays OTPs through the weekly bundles above, and pays office-based OUD care through G2086, G2087 and G2088. HCPCS G2213 covers starting OUD medication in an emergency department (CMS booklet).
Medicaid
The CMS fact sheet says Medicaid coverage depends on each state's plan, that states choose which codes to bill and that states decide which practitioners may provide services and set their qualifications. Every state manual is different. Check it before you bill a Medicaid SBIRT or counseling claim, and do not copy the Medicare codes across. A state rule that works for one claim type may not work for another, so substance use disorder billing needs a state-by-state note. If you need help reading a denial, the claim denial terms are a good start.
Private payers
Commercial plans set their own rules for SUD levels of care, medication coverage and prior authorization, and may use different code sets. Review the private insurance guides and your payer contracts. Our in-network versus out-of-network guide explains how network status changes what you can bill.
42 CFR Part 2 consent basics for substance use disorder billing
Part 2 is a federal privacy rule for certain SUD records, and it affects how you share records with payers.
HHS announced the final rule on February 8, 2024, and covered persons must comply by February 16, 2026 (HHS fact sheet, checked 10/10/26). The rule lets a patient sign one consent for all future uses and disclosures for treatment, payment and health care operations. That consent matters in substance use disorder billing because it covers sending records to a payer.
- Separate consent is still required for SUD counseling notes.
- Consent for legal proceedings cannot be combined with consent for other purposes.
- HIPAA covered entities and business associates that receive records under a treatment, payment and operations consent may redisclose them under HIPAA rules.
- The HIPAA Breach Notification Rule now applies to breaches of Part 2 records.
- Patients gain new rights, such as requesting restrictions on certain disclosures.
Whether Part 2 applies to your practice depends on whether you are a Part 2 program, which is a legal question. Ask your attorney or compliance officer. Our billing services overview explains what billing support covers, which is claims work, not legal review of consent forms.
7 steps for clean substance use disorder billing
Work through these before you submit SUD claims.
- Name your route. Decide whether you bill office visits, SBIRT, or run an OTP. The route sets every other choice in substance use disorder billing.
- Check enrollment. Confirm your license and payer enrollment fit the code. See the credentialing overview.
- Confirm Part 2 status. Ask counsel whether your records fall under Part 2 and store consents accordingly.
- Record time. For SBIRT, log start and stop times or total face-to-face time.
- Pick the payer's codes. Medicare uses G0396, G0397 and G2011. Medicaid and private plans may differ.
- Avoid duplicate billing. Do not bill separately for services an OTP bundle already pays for.
- Review the remittance. Read the electronic remittance advice and appeal wrong denials.
What to do Monday morning
Four jobs to tighten your substance use disorder billing this week.
- List the SUD services you bill and which payer and code covers each. Keep the list in one place so everyone doing substance use disorder billing uses the same codes.
- Ask your compliance contact whether Part 2 applies, and find where consents are filed. Consent gaps are a risk in any substance use disorder billing workflow.
- Add start and stop times to any SBIRT note template that lacks them.
- Pull recent SUD denials and sort them with the claim denials and appeals guide.
Frequently asked questions
What codes does Medicare use for SBIRT in substance use disorder billing?
Medicare lists G0396 for 15 to 30 minutes of structured assessment plus brief intervention, G0397 for more than 30 minutes, and G2011 for 5 to 14 minutes. The CMS SBIRT fact sheet does not list 99408 or 99409. Medicaid and commercial plans may choose different codes.
How are opioid treatment programs paid by Medicare?
Medicare pays OTPs through weekly bundles that combine the medication and non-drug services, such as G2067 for methadone and G2068 for oral buprenorphine. Add-on codes cover intake, assessments and take-home supplies. Only an entity enrolled as an OTP can bill these codes.
Does 42 CFR Part 2 apply to my substance use disorder billing?
It depends on whether you are a Part 2 program, which is a legal question. Ask your attorney or compliance officer. If it applies, HHS says covered persons must comply by February 16, 2026, and one consent can cover future treatment, payment and operations uses.
Can I bill counseling separately inside an OTP bundle?
Per CMS, counseling or therapy furnished by telecommunication cannot be billed separately by the practitioner because the OTP bundle already pays for it. The OTP reports additional counseling time in the week with add-on code G2080.
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Checked 10/10/26: CMS MLN904084: SBIRT services fact sheet (May 2025); CMS Transmittal 13572: Opioid treatment program payment changes (March 3, 2026); CMS MLN1986542: Medicare and Mental Health Coverage booklet (March 2026); CMS Transmittal 12425: Medicare IOP benefit; HHS: Fact sheet on the 42 CFR Part 2 final rule.