Interim treatment lets an OTP provide medication and some services to someone waiting for comprehensive treatment, for up to 180 days in any 12-month period. The OTP needs approval from both SAMHSA and its State Opioid Treatment Authority first, must plan continuing care by day 120, and must notify the SOTA when patients start, leave or transfer.
When an opioid treatment program (OTP) is full, people who need treatment may wait. Interim treatment is Part 8's answer: "on a temporary basis, a patient may receive some services from an OTP, while awaiting access to more comprehensive treatment services. The duration of interim treatment is limited to 180 days" (42 CFR 8.2). The 2024 rule expanded it, and SAMHSA's table of changes summarizes how: interim treatment "is now allowed at any qualifying OTP and the time frame for Interim Treatment was expanded from 120 to 180 days," while "state approval for use of interim treatment is still required."
What approvals does an OTP need first?
Two. "Before an OTP may provide interim treatment, the OTP must receive the approval of both the Secretary and the SOTA of the State in which the OTP operates" (42 CFR 8.11(f)(1)). SAMHSA cannot approve until the OTP gives it documentation from the State Opioid Treatment Authority showing that (8.11(f)(2)):
- The SOTA does not object to interim treatment in the state.
- The OTP cannot provide access to a comprehensive treatment program within a reasonable geographic area within 14 days of the time patients seek treatment.
- Authorizing interim treatment will not otherwise reduce the capacity of comprehensive programs in the state to admit people.
- The OTP will arrange each person's transfer to comprehensive treatment no later than 180 days from when the person first requested treatment.
SAMHSA then sends a notice approving or denying the request, and "the OTP shall not provide such treatment until it has received such notice" (8.11(f)(3)). Start with the SOTA; see working with your State Opioid Treatment Authority.
Who may be admitted to interim treatment?
The program sponsor may admit someone "who is eligible for admission to comprehensive treatment" when "comprehensive services are not readily available within a reasonable geographic area and within 14 days of the individual's seeking treatment" (8.12(j)(1)). The program must set written criteria for moving people from interim to comprehensive treatment, and those criteria must at minimum prioritize pregnant patients both for admission to interim treatment and for transfer into comprehensive treatment.
How is interim treatment different from comprehensive treatment?
All comprehensive treatment requirements apply, with these exceptions (8.12(j)(4)):
- A primary counselor is not required, but crisis services, including shelter support, should be available.
- Interim treatment "cannot be provided for longer than 180 days in any 12-month period."
- "By day 120, a plan for continuing treatment beyond 180 days must be created, and documented in the patient's clinical record."
- Formal counseling, vocational, employment, economic, legal, educational and other recovery support services need not be offered, but information about locally available community resources should be.
At least two drug tests are obtained during the maximum 180 days (8.12(j)(1)), and a person in interim treatment may not be discharged without an OTP practitioner's approval while awaiting transfer (8.11(f)(2)(iv)).
What must be reported to the state?
The program "shall notify the SOTA when a patient begins interim treatment, when a patient leaves interim treatment, and before the date of transfer to comprehensive services, and shall document such notifications" (8.12(j)(2)). Build those three notices into the workflow, with a log that a surveyor or the SOTA can check. The content of those notices is patient information governed by 42 CFR Part 2, so the consent and disclosure path should be settled in advance; see Part 2 consent and the Patient Notice.
Can the authorization be taken away?
Yes. SAMHSA "may revoke the interim authorization for programs that fail to comply" with the interim treatment rules (8.12(j)(3)).
Which policy pieces does interim treatment need?
- The approval record: the SOTA documentation and SAMHSA's notice.
- Eligibility and admission procedures tied to the 14-day availability test.
- Written transition criteria that prioritize pregnant patients.
- The day-120 continuing-care plan and the 180-day limit in any 12-month period.
- SOTA notification steps and the notification log.
- Crisis service and community resource information for interim patients.
- Discharge rules requiring OTP practitioner approval.
How do we help?
We draft the SOTA request package and the interim treatment policies as part of our Policy and Procedure Manual add-on ($1,495), cross-walked to 42 CFR 8.11(f), 8.12(j) and the state's OTP rule. The program sponsor requests SAMHSA approval, and admission and discharge decisions stay with the program's practitioners. We never receive patient information. See the 2024 rule and pricing.
Common questions
- Does interim treatment still need state approval after the 2024 rule?
- Yes. An OTP must have approval from both SAMHSA and the State Opioid Treatment Authority, and SAMHSA needs SOTA documentation that it does not object and that comprehensive treatment is not available nearby within 14 days.
- How long can a patient stay in interim treatment?
- No longer than 180 days in any 12-month period. By day 120 the program must document a plan for continuing treatment beyond 180 days.
- Does an interim patient need a primary counselor?
- No. A primary counselor is not required, but crisis services, including shelter support, should be available, and information about local community resources should be given.
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