A Policy Shift With Operational Consequences: What the NOPAIN Act Expansion Means for Your ASC

In 2026, separate reimbursement for non-opioid pain management alternatives continues to expand under the NOPAIN Act. The number of eligible products has increased from 11 in 2025 to 18 in 2026, giving ASCs more flexibility in postoperative pain management. 

At first glance, this may seem like a reimbursement update. 

In reality, it is an operational shift. 

Because these products receive separate payment, accurate documentation and claims reporting are no longer optional details. They are essential to capturing revenue and demonstrating utilization to CMS. 

Why Utilization Data Matters More Than Ever 

The data ASCs report today will shape what comes next.

The NOPAIN Act is currently authorized through 2027. CMS has made it clear that utilization data will play a key role in evaluating access, effectiveness, and the future of this policy. 

That data comes directly from ASC claims and documentation. 

If non-opioid alternatives are being used but inconsistently documented, the financial and policy impact may not be fully reflected. Incomplete reporting does not just affect reimbursement. It affects the broader case for continued access. 

This creates a new responsibility: clinical adoption must be matched with documentation accuracy. 

The Workflow Impact Inside Your Surgery Center 

More eligible products means more complexity.

As more non-opioid alternatives enter the ASC environment, medication workflows become more complex. Centers must manage accurate charge capture linked to the correct primary procedure, clear documentation that supports separate reimbursement, secure storage and controlled access, inventory visibility across cases and providers, and audit-ready reporting. 

This is not simply a billing issue. It is a coordination issue between clinical teams, pharmacy oversight, and revenue cycle processes. 

When tracking systems rely on manual logs or fragmented documentation, gaps can develop quietly. Those gaps often surface during audits, reimbursement reviews, or compliance assessments. A medication inventory management system gives ASCs the visibility and structure needed to close those gaps before they become a liability. 

Are Your Medication Logs Supporting Your Revenue Strategy? 

Documentation is your proof of performance. 

Separate reimbursement creates opportunities. But opportunities require visibility. 

ASC leaders should be asking: Can we clearly demonstrate when non-opioid alternatives were used? Are our medication logs consistent and standardized? If reviewed, could we confidently support our claims data? 

When medication management is structured, secure, and transparent, documentation becomes an asset rather than a risk. 

Turning Expansion into Preparation 

Is your operational infrastructure keeping pace? 

Expanded reimbursement for non-opioid alternatives supports patient access and clinical choice. But it also raises expectations around documentation discipline and operational consistency.

ASCs that align their reimbursement strategy with a reliable medication inventory management system will be better positioned to capture appropriate revenue, reduce documentation risk, strengthen compliance oversight, and contribute meaningful utilization data that informs future policy decisions.

Policy changes do not remain abstract. They move into daily workflows, medication storage, and claims systems.

The expansion of non-opioid reimbursement is here. The question is whether your systems are ready to support it.

MedServe helps ASCs build the documentation infrastructure to capture every eligible reimbursement and stay audit-ready as policies evolve. Ready to see how MedServe works in practice? Let's talk.