Ambulatory Surgery Billing Updates You Must Know for 2025

Medicare and CMS policies for 2025 bring significant changes for ambulatory surgery billing. For ASC medical billing services, this means revising revenue projections, payment calculators, and compliance checklists. Key updates include a 2.9% payment increase, new conversion factors, dozens of new CPT/HCPCS codes, and expanded non-opioid drug payments. 

This blog highlights how these changes impact your ambulatory surgery center billing and how ASC medical billing experts can help you stay compliant and maximize reimbursement.

1. CMS & Medicare Payment Rate Changes for 2025

CMS finalized a 2.9% update to ASC payment rates for CY 2025 (hospital market basket +2.9%, productivity -0.5%). This 2.9% increase applies to ASCs that meet the CMS quality reporting requirements; ASCs not meeting these requirements receive only a 0.9% update. 

ASCRS notes the 2025 ASC conversion factor will be $54.895 for reporting-compliant ASCs, versus $53.828 for non-compliant centers. In practical terms, an ambulatory surgery center billing team must update rate calculators and fee schedules to use the new conversion factor. Revenue forecasts should account for the higher pay rate (for compliant ASCs) and the risk of reduction for missed reporting.

Meeting quality metrics is critical: CMS enforces a 2% penalty on the annual update for failing ASCQR, effectively lowering reimbursement for non-reporters. Thus, ASC billing for ambulatory surgery centers must carefully track the status of their quality programs. In short, expect a roughly 3% pay boost (for compliant ASCs). Ensure your ASC billing staff applies the $54.895 factor in their claims software and write-off projections.

2. New & Updated CPT/HCPCS Codes

2025 brings many new procedures and supply codes. CMS issued quarterly addenda (Addenda AA, BB) with these updates. Notable changes:

• January 1, 2025 – CMS added 32 new separately payable ASC procedures. This includes 19 dental procedures moved onto the ASC list and other newly payable services. CMS also introduced two new HCPCS codes: C8002 (automated skin cell suspension autograft) and C8003 (implantation of a knee shock absorber). (All new January codes and rates are in CMS Addenda AA/BB.)

• Drug and biologic updates: 33 new drug/biologic codes took effect on 1/1/25, and 16 obsolete codes were deleted. Notably, 22 diagnostic radiopharmaceuticals were unpackaged and changed to ASC PI=K2 (now separately payable). Billing teams should review the January 2025 drug file (CMS Table 8–9) for these coding changes.

• April 1, 2025 – A new HCPCS code, C8004, was added for “simulation angiogram” for tumor radioembolization. Also, CPT codes 0446T and 0448T (diabetic implantable glucose sensors) had their ASC payment rates revised (with G0564/G0565 deleted). Importantly, five existing HCPCS drug codes changed to ASC PI=K2 (now separately reimbursable) as of April. Check Addendum BB (April 2025) for the updated rates and indicators.

• July 1, 2025 – CMS will implement the new CPT Category III codes released in January 2025. Sixteen new Category III codes will be payable in ASCs starting July 2025. A new CPT code, 11012, was also added to the bill, along with device code C1602 (breast biopsy cryoablation). Additionally, CMS grouped 13 new skin substitute codes into packaging categories and reassigned one code to the high-cost skin substitute group.
  

These quarterly updates mean your coding software and billing staff must refresh code sets each cycle. (CMS’s ASC Payment Rates & Addenda page lists all quarterly updates.) Missing a new code or rate can lead to denied claims or lost revenue. As a billing service provider, we ensure your clinic stays current by updating software and retraining coders on a quarterly basis, so no new codes are overlooked. That way, your ambulatory services in medical billing always use the latest CPT/HCPCS codes.

3. Non-Opioid Drugs & Devices: New Separate Payments

A major policy change is a separate payment for certain non-opioid pain treatments (Section 4135 of the CAA). Starting January 1, 2025, eligible non-opioid drugs and biologics used as surgical supplies will be paid separately in the ASC setting. Notable examples:

• Omidria (J1097) and Dextenza (J1096) – these two non-opioid ophthalmic agents now each have an ASC payment cap (~$428). CMS confirmed these products qualify for the separate-pay policy, so ASC billing must report J1097/J1096 to receive payment (instead of bundling them).

• C9088 – a new non-opioid nasal spray, got separate-pay status effective April 2025 when its transitional pass-through expired.
  

In practice, your coding team should list eligible J-codes as separate line items with the appropriate ASC PI=K2 indicator (or apply the capped payment). For example, if Omidria is used, bill J1097 is received, and the approximately $428 payment is made.

4. Packaging Policies & Pass-Through Marker Changes

Several devices and products moved between packaged status and separate pay. A key example is HCPCS C1739 (breast tissue marker): CMS initially packaged C1739 (no ASC pay) as of January 2025, since it didn’t accompany any covered surgery by itself. However, CMS later allowed separate ASC payment for C1739 when paired with specific procedures. Beginning January 1, 2025, if billed with skin biopsy CPT codes (19081, 19083, 19085), C1739 is payable with ASC PI = J7. In other words, claims with C1739 plus 19081/3/5 will now get payment rather than a denial. Our billing team will adjust the claim logic to apply PI = J7 when those code combinations appear.

Skin substitute products also saw packaging changes. By default, most skin substitutes are packaged into the application procedure (ASC PI=N1). For CY2025, CMS defined “high-cost” vs “low-cost” groups based on price. The April 2025 update added 14 new HCPCS skin substitute codes (all packaged, N1) and reclassified one code into the high-cost group. In July, 13 new skin substitute codes were activated, with most assigned to the low-cost group. ASC coders must note the PI groups, and none of these skin-substitute codes generate a separate pay; claims with N1 codes are not reportable in ASCs.

Overall, billing for ambulatory surgery centers must now take into account these packaging revisions. Besides C1739, watch for any pass-through devices that CMS “unbundled” or “rebundled.” In summary, review each drug/device’s ASC Payment Indicator (PI) in the current addenda. As your billing services partner, we verify procedures against the latest packaging policy tables to ensure accurate billing (e.g., omitting fully packaged items or capturing newly separate-pay items).

5. Quality Reporting Requirements & Incentives

ASCs participate in the ASC Quality Reporting (ASCQR) program. CMS requires reporting certain quality measures or face a cut in the annual update. Meeting reporting requirements yields the full 2.9% increase ($54.895 CF) while non-reporting ASCs lose 0.1% of that (getting only $53.828). In practice, missing ASCQR reporting costs you money. Our ASC billing teams advise clients to confirm the quality of their submissions (e.g., Q4 2024 data) to ensure they secure the full conversion factor.

CMS is also introducing new quality measures for 2025, with a focus on equity. Three measures were finalized for ASCQR: “Facility Commitment to Health Equity” (mandatory for 2025), and two social-determinants-of-health (SDOH) screening measures (voluntary in 2025, mandatory in 2026). These require ASCs to track health equity and social needs data. While they don’t yet affect 2025 payments, they signal where CMS is heading. We recommend involving your quality managers early so that data flows are in place. A billing team often helps by flagging these measures and coordinating with compliance officers to avoid future penalties.

In summary, maintaining ASC quality compliance is now tightly tied to reimbursements. If you miss reporting deadlines, CMS will reduce your update (as clearly shown by the lower conversion factor for non-compliant ASCs). Our experts help you track deadlines, submit required measures, and prepare for new equity reporting, keeping you on the “good” conversion factor track and avoiding revenue loss.

6. CPT Code Packaging Corrections & Addenda Fixes

CMS issued a correcting amendment in January 2025 to correct several coding and payment errors. Key corrections affecting ASC billing:

• Skin Cell Suspension (CPT 15013, C8002): The final OPPS/ASC rule had a mis-assigned APC for the new skin cell suspension codes. CMS corrected the APC from Level 30 to Level 32 and updated the ASC payment weight/rate in Addendum AA. This means the payment for CPT 15013 and HCPCS C8002 is slightly higher than originally published. ASC billing systems must use the revised payment rate in April 2025 claims.

• Brachytherapy Products (HCPCS C1717, C2616, C2634, etc.): Several brachytherapy source codes were incorrectly priced for ASC. CMS adjusted those rates to the proper geometric mean costs. If your ASC performs ophthalmic or vascular brachytherapy, use the corrected rates.

• Other fixes: A payment rate for CPT 53865 (ureteroscopy) was updated to the correct APC. Descriptors and rates for a handful of drugs and radiopharmaceuticals were also corrected.
  

These adjustments were made via the OPPS/ASC final rule errata (“correction notice”) and the updated Addenda. For billing teams, it is critical to download the corrected Addenda AA/BB from CMS and reconcile your charge table. For example, if a claim with CPT 15013 was paid at the old rate, you may need to re-bill or appeal using the revised weight from Addendum AA. Our billing service closely monitors these changes to ensure that your claims always use the current, corrected payment rates. In practice, we recommend checking CMS’s published “Addenda and supporting files” (zipped AA/BB) whenever CMS issues a correction, to catch any rate changes that could affect your reimbursements.

7. What’s Next? Emerging Trends & Forecasts

Looking beyond 2025, CMS is moving towards value-based purchasing (VBP) for ASCs. The ACA mandates a plan for ASC VBP, and CMS’s 2025 Report to Congress outlined steps (pending future rulemaking). In short, Medicare may start tying ASC payments to quality and outcomes rather than volume. ASC billing teams should remain vigilant to policy developments surrounding VBP, as billing practices and incentives may evolve (e.g., shared savings or penalties based on cost and quality metrics).

Another trend is the expansion of the ASC-covered procedures list. Stakeholders, like the Heart Rhythm Society, are pushing CMS to add more advanced procedures (for example, cardiac ablations) to ASC eligibility. While ablations were again not included in 2025, industry groups expect more procedural inclusions over time. A savvy ASC billing department will track Federal Register announcements on ASC coverage. Each new covered procedure requires adding relevant CPT codes to your system and confirming licensing and infrastructure.

Finally, continued technological and billing innovations are expected to impact ASC billing in 2026. For instance, if CMS allows more telehealth or remote monitoring in ASCs (following COVID-19 waivers), billing teams will need to adapt their coding for those services. Keeping an eye on proposals in the CY2026 physician fee schedule and outpatient final rules will help anticipate new codes or policies. In short, billing for ambulatory surgery centers will increasingly intersect with quality data, equity measures, and tech-enabled care. 

Tips for Billing Teams: 2025 ASC Readiness Checklist

• Update Fee Schedules: Apply the new conversion factor ($54.895) and a 2.9% rate increase for compliant ASCs; use $53.828 for non-reporting ASCs. Adjust all prices and pricing tables accordingly.

• Refresh Code Sets: Load the new CPT and HCPCS codes (C8002, C8003, C8004, Category III codes, new skin/skin substitute codes, etc.) into your encoder and billing software. Remove deleted codes.

• Reevaluate Packaging: Review which codes are now packaged (PI=N1) versus those that are separate (PI=K2/J7). In particular, update coding logic for C1739 (now payable with certain CPTs) and apply packaging status for all new skin substitutes and radiopharmaceuticals.

• Ensure Quality Reporting Compliance: Confirm ASCQR submission is on track for the 2024 performance year. Document new equity measures (Facility Commitment to Equity, SDOH screens) to prepare for future mandatory reporting.

• Monitor CMS Addenda: Download the ASC Addenda AA/BB for new codes and rates quarterly (January, April, July, and October). Adjust claims systems immediately when updates are issued.

• Train Billing Staff: Conduct a brief training session on these updates. Ensure coders know about new CPT/HCPCS codes, payment changes, and how to bill non-opioid drugs correctly. Clear any confusion on packaging rules.
  

By following this checklist, your ASC billing department will be well-prepared for the changes in 2025. 

Conclusion

The CY 2025 ASC rule introduces higher payments but also adds complexity to ambulatory surgery center billing. The net effect on revenue will depend on meeting new quality requirements and properly leveraging new codes and separate-pay provisions. Mistakes in coding or missed reporting can result in reduced reimbursement. That’s why partnering with experienced ASC medical billing services can mitigate risks.

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