September 4, 2025: CMS to Implement Prior Authorization ASC Demonstration Project
As reported last year, CMS will initiate a five-year demonstration project that will require ASCs to receive prior authorization from Part B Medicare carriers for five services, including Blepharoplasty, Blepharoptis Repair, and Brow Ptosis Repair and Botulinum Toxin Injection. The project will encompass these services in the following states: California, Florida, Texas, Arizona, Ohio, Tennessee, Pennsylvania, Maryland, Georgia, and New York.
In 2024, OOSS joined the American Academy of Ophthalmology (AAO) and the American Society of Ophthalmic Plastic and Reconstructive Surgery (ASOPRS) in a letter to CMS, strenuously urging that the agency halt implementation of the Demonstration. Among our key points:
- The hospital outpatient department PA program must be further evaluated and improved before extending PA to surgery centers.
- CMS should remove all ophthalmic procedures (i.e., the codes listed under (i) Blepharoplasty, Blepharoptosis Repair, and Brow Ptosis Repair and (ii) Botulinum Toxin Injection) from the ASC PA Demonstration.
- The agency has significantly understated the true administrative burden of compliance with the Demonstration and overlooks many other problems associated with PA, including treatment delays and blocked patient access to medically necessary care.
- Since the ASC does not possess the requisite patient records that support the need for surgery, CMS should clarify that the practice, not the ASC, is responsible for obtaining the PA.
Nonetheless, CMS is moving forward with this program commencing December 2025. We will keep you abreast of compliance requirements and further developments.
In the meantime, should you have any questions, please contact Michael Romansky, OOSS’ Washington Counsel, at mromansky@OOSS.org.
To review CMS’ announcement of the PA program: https://www.cms.gov/data-research/monitoring-programs/medicare-fee-service-compliance-programs/prior-authorization-and-pre-claim-review-initiatives/prior-authorization-demonstration-certain-ambulatory-surgical-center-asc-services.