November 20, 2025: CMS to Delay Implementation of ASC Prior Authorization (PA) Demonstration Project Until Early in 2026

As we have been reporting, 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. The agency had planned on initiating implementation on December 15, 2025. After meetings with and submissions be AAO, OOSS, and organizations representing the oculoplastics community, CMS is delaying this initiative as follows: 

  • Providers in California, Florida, Tennessee, Pennsylvania, Maryland, Georgia and New York can submit PA requests beginning on January 5, 2026 for dates of service on or after January 19, 2026.
  • Providers in Texas, Arizona, and Ohio can submit PA requests beginning on February 2 for dates of service on or after February 16.

We continue to have concerns about how the administration of the PA demo project and will continue to advocate for changes in the program. We will keep you abreast of further developments.

Should you have any questions, please contact OOSS General Counsel Michael Romansky at mromansky@OOSS.org

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