Audit of the Office of Medicaid (MassHealth) - Review of Counseling Provided to MassHealth Members Receiving Medication-Assisted Treatment for Opioid Use Disorders
March 21, 2019 · Office of Medicaid (MassHealth) · Read the full official report on mass.gov ↗ · official site ↗
Published March 21, 2019 Audit covers January 1, 2011 – December 31, 2015 Under Suzanne M. Bump · 2011–2023
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“Using data analytics, we found that approximately 7,000, or 27%, of the MassHealth members treated with buprenorphine from January 1, 2011 through December 31, 2015 did not receive any type of opioid use disorder counseling.”
Read the plain-English breakdown
This is a Massachusetts State Auditor performance audit of MassHealth’s handling of counseling for members receiving medication-assisted treatment for opioid use disorder.
“OSA has conducted an audit of opioid use disorder counseling provided to MassHealth members who received buprenorphine under any brand or generic name as part of their medication-assisted treatment (MAT) for opioid use disorders for the period January 1, 2011 through December 31, 2015.”
Auditors wanted to know whether people receiving buprenorphine through MassHealth were also getting, or at least able to get, counseling that could help their recovery.
“The purpose of this audit was to determine whether MassHealth members received and/or had access to appropriate and necessary counseling to aid in their recovery from opioid use disorders.”
Opioid addiction was a major public health issue in Massachusetts, and the report says opioid-related deaths rose sharply during the audit period.
“Further, a 2016 Department of Public Health (DPH) publication titled Data Brief: Opioid-Related Overdose Deaths among Massachusetts Residents reported that the rate of unintentional opioid-related deaths of Massachusetts residents4 rose from 9.3 to 25.8 deaths per 100,000 residents from 2011 through 2015, as shown below.”
For residents and taxpayers, this matters because MassHealth serves many people and makes up a large part of the state budget.
“Medicaid expenditures represent approximately 39% of the Commonwealth’s total annual budget.”
The auditor’s main conclusion was that some members did not receive recommended counseling, some counseling may not have been from addiction-trained professionals, and some prescribers lacked proper documentation.
“Prescribers did not always maintain documentation supporting medical visits where prescriptions were given to MassHealth members.”
The auditor recommended that MassHealth improve access to counseling, look into barriers, work with public health officials on counselor training, and review poorly documented prescribers for possible payment recovery.
“MassHealth should conduct a review of these prescribers’ medical documentation and recover any payments for services that were not properly documented.”
The report is significant because it points to gaps in treatment access and oversight during a period when Massachusetts was dealing with serious opioid-related harm.
“Opioid use disorders are a significant problem in Massachusetts.”
Medication-assisted treatment means using medicine, such as buprenorphine, along with counseling to help people manage opioid addiction and recovery.
“According to the federal Substance Abuse and Mental Health Services Administration (SAMHSA), medication-assisted treatment (MAT) for opioid use disorders consists of a combination of prescription medication and outpatient opioid use disorder counseling to provide patients with behavioral coping skills to treat their disorders.”
2 figure(s) pending source verification - not shown
What the Auditor checked
- Did not comply Do MassHealth members who are treated with buprenorphine for opioid use disorders receive, or have access to, appropriate and necessary counseling?
What the Auditor found
Why it matters: Some members may not have received comprehensive counseling while being treated for opioid use disorders.
Standard: ASAM recommends that qualified substance abuse counselors possess expert knowledge, training, and education in addiction medicine.
1 recommendation
- MassHealth should collaborate with DPH to ensure that opioid use disorder counselors have the proper training, skills, and knowledge to provide effective opioid use disorder counseling.agency: disagreed
Agency response & Auditor reply
Agency: "MassHealth agrees that practitioners providing counseling, and other services, to members with OUD should be qualified and well trained, but disagrees with this OSA finding."
Auditor: "We do not dispute this fact, but as noted above, MassHealth does not specifically identify what type of education or certification counselors should obtain to provide counseling to members recovering from opioid use disorders."
Why it matters: The lack of documentation for a highly addictive controlled substance creates a risk that members could misuse the substance and that MassHealth paid for unsupported services.
Standard: 130 CMR 433.409(D)(1) requires documentation of medications prescribed, including strength, dosage, and regimen; 130 CMR 450.205(A) states MassHealth will not pay for services without adequate documentation. ( Section 433.409(D)(1) of Title 130 of the Code of Massachusetts Regulations; 130 CMR 450.205(A) )
1 recommendation
- MassHealth should conduct a review of these prescribers' medical documentation and recover any payments for services that were not properly documented.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth agrees with OSA’s recommendation that an additional review of these five prescribers is warranted based on the apparent lack of medical documentation."
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