The ambulatory surgery center (ASC) remains one of the most strategically important components of ophthalmic practice economics. Cataract, glaucoma, corneal, and other anterior-segment procedures rely heavily on facility-based reimbursement, predictable case volumes, and efficient surgical throughput—making ASCs essential to both financial stability and patient access in ophthalmology. With Medicare’s 2026 payment policies now finalized, ophthalmology groups must adapt their operational, clinical, and financial strategies to protect margins while meeting rising administrative requirements and heightened payer scrutiny. This expanded article provides a comprehensive review of the most significant 2026 Medicare changes affecting ophthalmology ASCs and outlines actionable steps practices can take to optimize reimbursement, strengthen case mix, improve documentation, and negotiate effectively with payers.¹

What’s Changing in 2026

CMS’s 2026 updates reflect an ongoing push toward consistency between ASC and hospital outpatient department (HOPD) payment systems. For the seventh consecutive year, CMS is applying the hospital market basket to ASCs, resulting in an estimated 2.4% payment increase for ASC facility services.² Although this increase is modest, it represents a continued policy stance that incentivizes the migration of appropriate procedures from the higher-cost hospital setting to the more cost-effective ASC environment—an important consideration for ophthalmology, which already performs a large percentage of Medicare’s outpatient surgical volume.

CMS also signaled a meaningful expansion of the ASC Covered Procedures List (ASC-CPL). Several ophthalmic procedures that were previously restricted to HOPDs may now qualify for ASC payment, offering new opportunities for case migration.³ These additions reflect growing confidence in the safety, efficiency, and patient satisfaction associated with ophthalmology ASCs. Practices prepared to operationalize new procedures—particularly in glaucoma and cornea—may see measurable gains in ASC case mix and overall profitability.

CMS’s proposed expansion of the ASC Covered Procedures List (ASC-CPL) for 2026 represents one of the most significant strategic opportunities for ophthalmology groups. Historically, CMS has taken a measured, conservative approach when adding ophthalmic procedures to the ASC-CPL, prioritizing patient safety, anesthesia risk, and postoperative care needs. However, the 2026 rule signals greater confidence in the ability of ASCs—particularly ophthalmic-focused centers—to deliver safe, predictable, and cost-effective surgical care.

Although final additions will be confirmed in the Final Rule, early policy signals and specialty-society analyses suggest that several procedure categories may see expanded ASC eligibility, including the following:

• Selective and minimally invasive glaucoma surgeries (MIGS) beyond the most common CPT codes; 

• Glaucoma drainage implants and revisions for select patient profiles; 

• Anterior-segment reconstruction procedures, including certain corneal wound repairs; 

• Additional corneal transplant–related procedures, especially partial-thickness techniques; and 

• Complex cataract add-on work (eg, certain anterior vitrectomy codes); and 

• Laser-based ophthalmic procedures traditionally restricted to HOPDs.

These additions are driven by 2 factors:

1. Ophthalmology’s strong safety record in ASCs. CMS has increasingly acknowledged that ophthalmology has among the lowest surgical complication rates in the ASC environment. This consistent track record supports shifting more procedures to ASCs where clinically appropriate.

2. Alignment with CMS’s broader cost-saving strategy. ASCs routinely perform ophthalmic procedures at 40% to 60% lower cost than HOPDs. Expanding the ASC-CPL allows CMS to reduce Medicare expenditures while maintaining access and quality—benefiting both the program and patients through reduced copays.

For ASCs, newly eligible procedures can materially improve case mix by adding mid-acuity surgeries that generate meaningful facility reimbursement. However, practices must prepare in advance by evaluating anesthesia protocols, equipment needs, staff training requirements, and payer-contract implications. Groups that proactively model reimbursement, safety, and workflow impacts will be best positioned to take advantage of ASC-CPL expansion.

On the professional payment side, the 2026 Medicare Physician Fee Schedule (PFS) introduces multiple RVU revaluations and practice expense adjustments. These changes affect ophthalmology unevenly, with some commonly performed CPT codes experiencing shifts in non-facility and facility RVUs.¹ Because ophthalmologists rely heavily on a predictable set of surgical CPT codes, even small professional reimbursement changes have financial consequences across hundreds or thousands of cases annually.

Finally, CMS continues to expand prior authorization demonstration programs into the ASC setting. Requirements now touch a broader range of ophthalmic procedures, increasing administrative workload and making accurate, defensible documentation more important than ever.⁴

Why Ophthalmology Practices Must Act Now

Ophthalmology is uniquely exposed to the financial effects of reimbursement shifts due to:

• High procedure volumes. Cataract surgery is among Medicare’s highest-volume procedures, and many ophthalmology practices rely on a consistent surgical pipeline.

• Dependence on facility-based payments. ASC facility fees are central to ophthalmic economics, especially for cataract, glaucoma, and corneal surgeries.

• Predictable utilization patterns. Unlike other specialties with fluctuating case mix, ophthalmology’s volume stability means that small rate adjustments—positive or negative—compound significantly over time.^5,6

• Opportunity from an expanded ASC-CPL. More ASC-eligible procedures can meaningfully improve case mix, but only for organizations that can rapidly adapt workflows, anesthesia coverage, supply chains, and payer communication. ¹

Practical Reimbursement Strategies for 2026

1. Analyze case mix and prioritize ASC-eligible procedures. A deliberate, data-driven case-mix analysis is foundational. With the anticipated ASC-CPL additions, practices should evaluate the following:

• Clinical suitability of specific procedures for ASC performance;

• Expected reimbursement differences between ASC and HOPD settings;

• Surgeon capacity to absorb expanded ASC volume;

• Impact on anesthesia resource utilization; and

• Patient financial responsibility in each setting.

Case migration should focus on procedures where clinical appropriateness aligns with favorable reimbursement. Practices that routinely evaluate throughput, operative times, and per-case profitability will be better positioned to capitalize on ASC-CPL changes.^3,7

2. Strengthen documentation and coding for prior authorization and audits. Medicare’s expanding prior authorization environment directly affects cataract and glaucoma surgeries.⁴ To streamline approvals and withstand audits, documentation should include the following:

• Objective visual acuity impairment,

• Functional limitations affecting daily activities,

• Symptom progression over time,

• Diagnostic imaging validating the diagnosis,

• Attempts at conservative therapy (when applicable), and

• Clear surgical justification.

Surgeon-friendly templates can standardize documentation, improve accuracy, and reduce prior authorization delays. Practices with well-built templates often see improved approval rates and fewer post-payment reviews.

3. Re-Examine Payer Contracts Through an ASC Lens. Commercial payers vary widely in how they value ophthalmic ASC procedures. Practices should do the following:

• Compare current ASC and HOPD reimbursement for high-volume CPT codes,

• Model projected payment under 2026 RVUs,^6,1

• Identify underperforming payer contracts suppressing ASC profitability,

• Renegotiate high-cost implant carveouts¹⁰, and

• Consider bundled cataract payment arrangements.^7,8

Quality outcomes and low complication rates give ASCs strong leverage for higher commercial ASC reimbursements.

4. Optimize supply chain and drug/device management. Supply costs represent one of the largest controllable expenses in ophthalmic ASCs. Key drivers include IOLs, viscoelastic materials, MIGS devices, and glaucoma implants. Centralized purchasing, formulary standardization, and tight inventory control reduce per-case costs. Staying current on CMS drug addendum updates ensures accurate billing and pass-through reimbursement.⁹

5. Invest in revenue-cycle automation and denial prevention. Automation improves efficiency across eligibility checks, prior authorization workflows, supply charge capture, and coding validation. These tools minimize denials and reduce staff burden—especially important as case volume grows.⁷

6. Model sensitivity to RVU and PFS changes. Because the 2026 PFS modifies RVUs for several ophthalmic CPT codes, practices should model the following:

• High-volume CPT payment variation,

• Professional vs facility revenue shifts,

• Site-of-service reimbursement differences, and

• Staffing and equipment cost impact.

American Academy of Ophthalmology and American Society of Cataract and Refractive Surgery analyses provide insight for accurate modeling.^5,6

7. Build an advocacy and comment strategy. Ophthalmology’s professional societies play a central role in shaping CMS policy. Practices should participate by submitting data-driven comments and staying engaged through the regulatory cycle.^{3,12 2,6}

Contracting Strategies and Value-Based Reimbursement

Commercial payers increasingly prioritize value, outcomes, and efficiency. Ophthalmology ASCs are positioned favorably due to predictable surgical pathways and excellent outcomes. When negotiating ASC-friendly contracts, ASCs should highlight lower per-episode costs, shorter recovery times, high patient satisfaction, and low complication rates.¹⁰

Bundled Payment Opportunities

Cataract surgery is also ideal for bundles because of consistent outcomes and low complication rates.⁸

Quality metrics can be leveraged in negotiation. Payers expect low postoperative complications, few return-to-OR events, and strong patient-reported outcomes (PROs). Ophthalmic ASCs often outperform these benchmarks.¹¹ Ophthalmic ASCs can also consider shared savings and quality-based reimbursement models, which continue expanding into ophthalmology.^10,2,1212

Practical Steps for 2026

This year, practices should work toward key goals that include developing dashboards to track outcomes,¹¹ identifying supply cost savings, training staff in value-based payment structures,¹³ and pursuing multiyear payer agreements for stability.¹³ Before adding or migrating procedures, practices must ensure licensing and accreditation compliance, adequate anesthesia and nursing staffing, emergency transfer plans, and capital investment that is aligned with expected growth.¹⁴

Conclusion

The 2026 Medicare policy environment presents ophthalmology ASCs with both meaningful opportunities and operational challenges. The proposed expansion of the ASC Covered Procedures List (ASC-CPL) reflects CMS’s growing confidence in the safety, efficiency, and cost-effectiveness of ophthalmic surgery performed in the ASC setting. If finalized, these additions particularly in glaucoma, cornea, and complex anterior-segment categories have the potential to strengthen ASC case mix and expand mid-acuity procedural volume.

At the same time, shifting procedures to the ASC demands preparation. Practices must evaluate anesthesia protocols, equipment requirements, staffing capabilities, and payer-contract implications to ensure safe and financially sound implementation. Success will depend on rigorous modeling, forward-looking operational planning, and clear communication with commercial payers about ASC value.

In parallel, 2026 PFS adjustments, evolving prior-authorization rules, and intensifying payer scrutiny require ophthalmology groups to elevate documentation quality, strengthen revenue-cycle workflows, and negotiate smarter contracts that reflect ASC efficiency and outcomes. ASCs that can demonstrate strong clinical performance—low complication rates, high patient satisfaction, and predictable surgical pathways—will be best positioned to secure favorable reimbursement in both fee-for-service and emerging value-based models.

Ultimately, the practices that treat regulatory change as a strategic lever rather than a compliance burden will benefit most. By aligning case mix, operational readiness, financial modeling, and payer strategy, ophthalmology ASCs can convert the 2026 policy landscape into durable competitive advantage.

Rebecca Greenlaw, CPC, CPCO, COPC Rebecca Greenlaw, CPC, CPCO, COPC, is a coding and compliance specialist with more than a decade of experience in ophthalmology. She began her career in 2012 in a front office role before advancing into technician, scribe, and medical chart auditing positions. Rebecca later transitioned into quality assurance, supporting clinic and ASC coding opera-tions, and ultimately leading coding teams across south Florida. She joined Corcoran Consulting Group in 2025.

References

1. Centers for Medicare & Medicaid Services. CY 2026 Medicare physician fee schedule (PFS) final rule (CMS-1832-F). October 31, 2025. Accessed February 23, 2026. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule-cms-1832-f 

2. Value-Based Reimbursement: Passing Trend or the New Normal? Ophthalmology Management.  August 1, 2019. Accessed February 23, 2026. https://ophthalmologymanagement.com/issues/2019/august/value-based-reimbursement-passing-trend-or-the-new-normal/ 

3. Ambulatory Surgery Center Association. CMS releases 2026 proposed payment rule. July 15, 2025. Accessed February 23, 2026. https://www.ascassociation.org/news-2026-proposed-payment-rule 

4. LeValley D. Medicare prior authorization expands to ambulatory surgical centers. Kiplinger. September 5, 2025. Accessed February 23, 2026. https://www.kiplinger.com/retirement/medicare/medicare-prior-authorization-expands-to-ambulatory-surgical-centers 

5. American Academy of Ophthalmology. MS proposes 2.4% pay increase for hospital outpatient departments, ASCs for 2026. July 17, 2025. Accessed February 23, 2026. https://www.aao.org/advocacy/eye-on-advocacy-article/cms-pay-increase-hopd-asc-proposed-2026 

6. American Society of Cataract and Refractive Surgery. 2026 Medicare physician fee schedule proposed rule released. July 14, 2025. Accessed February 23, 2026. https://www.ascrs.org/news/ascrs-news/2026-medicare-physician-fee-schedule-proposed-rule-released 

7. Devaraj V. Decoding the 2026 OPPS/ASC proposed rule: what CFOs need to know about payment shifts. Plutus Health. February 4, 2026. Accessed February 23, 2026. https://www.plutushealthinc.com/post/decoding-the-2026-opps-asc-proposed-rule-what-cfos-need-to-know-about-payment-shifts 

8. Coffin J, Esfahani S. Bundled payment programs and ambulatory surgical centers. March 15, 2022. Accessed February 23, 2026. https://www.mgma.com/articles/bundled-payment-programs-and-ambulatory-surgical-centers 

9. Centers for Medicare & Medicaid Services. MM13934—ambulatory surgical center payment update. March 25, 2025. Accessed February 23, 2026. https://www.cms.gov/files/document/mm13934-ambulatory-surgical-center-payment-update-january-2025.pdf 

10. Dorsey A, Todd E. Managed care contracting for ASCs: navigating trends for financial success. October 3, 2024. Accessed February 23, 2026. https://www.smpsd.com/blog/mastering-managed-care-contracting-for-ascs/ 

11. Preparing for fee-for-value. Ophthalmology Management. October 1, 2019. Accessed February 23, 2026. https://ophthalmologymanagement.com/issues/2019/october/preparing-for-fee-for-value/ 

12. Nimbler RCM. Beyond fee-for-service: navigating advanced payment models and payer trends for ASCs. Accessed February 23, 2026. https://nimblercm.com/beyond-fee-for-service-navigating-advanced-payment-models-and-payer-trends-for-ascs/ 

13. Physicians Advocacy Institute. Guide to Value-Based Contracting. Accessed February 23, 2026. https://www.physiciansadvocacyinstitute.org/Portals/0/assets/docs/Value-Based-Arrangement-Resources/APM%20Guide%20to%20Value-Based%20Contracting.pdf 

14. Centers for Medicare & Medicaid Services. Ambulatory surgical center (ASC) payment. July 29, 2025. Accessed February 23, 2026. https://www.cms.gov/medicare/payment/prospective-payment-systems/ambulatory-surgical-center-asc