Hospital Outpatient Department (HOPD) Payment

The Academy believes hospital outpatient department (HOPD) payments should be tied to the actual cost of performing services, rather than broader budgetary factors such as Medicare budget neutrality requirements. The Academy also supports use of the most cost-effective setting for surgical services when outcomes are comparable — while recognizing that the choice of treatment setting should ultimately rest with the physician and patient. 

As with the Medicare Physician Fee Schedule, the Academy reviews and comments on each year's proposed HOPD payment policy updates. We work to ensure that the Centers for Medicare & Medicaid Services’ (CMS) decisions are based on accurate data and a thorough understanding of ophthalmic surgical practice.

In 2025, the Academy joined OOSS, ASCRS, and ASRS in identifying a critical error in CMS's proposed 2026 ASC payment rates for cataract surgery. CMS's rate-setting programs had inadvertently failed to import the billing codes for intraocular lens (IOL) devices, causing IOL costs to be excluded entirely from the cataract surgery payment calculation. The proposed rule would have cut cataract surgery facility fees by 4.7%. After the ophthalmology community flagged the error, CMS corrected its methodology — reversing the proposed cut and finalizing a 3.4% increase over 2025 rates instead. The Academy's advocacy prevented nearly $125 million in cuts to cataract surgery facility reimbursement in 2026.

Many ophthalmic surgical procedures are performed in HOPDs, making HOPD payment policy a significant issue for ophthalmologists and their patients. CMS sets payment rates differently depending on where a patient receives care, and rates are updated annually through a formal rulemaking process.

Recently, policymakers' focus has been on site neutrality — a policy approach that would allow Medicare to pay the same rate for a service regardless of care setting. Past site neutrality policies have focused on aligning payments to off-campus HOPDs, which are operated by hospitals or health systems, with those made to freestanding physician offices under the Medicare Physician Fee Schedule. The Academy monitors site neutrality proposals closely, as payment disparities between settings have significant implications for where ophthalmologists can provide surgical care. 

Each summer, CMS publishes a proposed rule with HOPD and ambulatory surgical center (ASC) rates for the following calendar year. Final versions of both the HOPD/ASC rule and the Medicare Physician Fee Schedule are published each fall, with rates taking effect on January 1.