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What an OTP and methadone clinic EMR has to record

Updated 2026-10-17

An OTP is not a general outpatient chart

An opioid treatment program (OTP) dispenses medications for opioid use disorder, including methadone, under 42 CFR Part 8. The medical record has to support dosing, attendance, and the decision to send medication home. A generic ambulatory chart does not do that by itself.

Federal standards in 42 CFR 8.12 require medication to be administered or dispensed by a practitioner licensed under state law and registered under the applicable state and federal laws, or by an agent of that practitioner under the practitioner's order. Methadone in an OTP is administered or dispensed only in oral form, formulated to reduce the chance it will be injected.

What the dosing record has to hold

For a new patient, the initial methadone dose is individual. The first-day total should not exceed 50 milligrams unless the OTP practitioner documents a medical reason for a higher dose, including a verified transfer from another OTP. Significant departures from FDA labeling have to be documented in the record.

That is a record-keeping problem as much as a clinical one. The chart needs the order, the amount dispensed, who dispensed it, and the reason when the usual limit is exceeded. This page describes the federal standard. It is not legal advice, and state rules can be stricter.

What Health OS documents today

Health OS is MASE's electronic medical record for behavioral health and opioid treatment programs. Its product site is https://www.mase-emr.com. The workflows MASE publishes for Health OS are a dosing-window workflow, inventory counts whose corrections require two staff members plus a separate approver, and overrides that require a human e-signature. Alerts are decision support only. The software does not make the clinical decision.

MASE does not publish a separate methadone-dispensing module, a take-home calculator, or a claim that Health OS files regulatory reports. Take-home decisions are covered in the related article. Health OS is live as part of MASE at Serenity Rehabilitation Center in Pontiac, Michigan, and at one practice in Texas. Those are the only live sites this page states.

Sources

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