CMS Delays Start Date for ASC Prior Authorization Demonstration

November 21, 2025

The Centers for Medicare & Medicaid Services (CMS) has delayed the start date for the ASC prior authorization demonstration and will implement the demonstration in two phases. CMS had previously announced the demonstration would start on December 15, 2025. The demonstration project impacts the following 10 states: Arizona, California, Florida, Georgia, Maryland, New York, Ohio, Pennsylvania, Tennessee and Texas.

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

CMS first proposed this demonstration project in February 2024. ASC providers will have to submit documentation to their Medicare Administrative Contractors (MAC) that shows a service meets applicable Medicare coverage, coding and payment rules prior to rendering the service. There are 41 codes that will be subject to the demonstration, which fall within the following categories:

  • Blepharoplasty, Blepharoptosis Repair, and Brow Ptosis Repair
  • Botulinum Toxin Injection
  • Panniculectomy, Excision of Excess Skin and Subcutaneous Tissue (including Lipectomy), and related services
  • Rhinoplasty, and related services
  • Vein Ablation, and related services

Last month, ASCA sent a letter to CMS requesting a delay, citing concerns about the demonstration project, including the capacity for MACs to handle prior authorization request volume.

More information is available in CMS’ operational guide and frequently asked questions document. ASCA has also published an ASC Focus Digital Debut article and ASCA Audio Update episode covering the demonstration.

Please contact Kara Newbury with any questions.