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NOPAIN Act FAQ
Quick answers on the NOPAIN Act — what it is, what qualifies, who gets paid, and how long it lasts. In short: the Act gives hospitals and surgery centers a separate Medicare payment for qualifying non-opioid pain management used during outpatient surgery, in effect from January 1, 2025 through December 31, 2027. As of January 1, 2026, qualifying devices include the Game Ready GRPro 2.1 cold + compression system.
For the full picture, start with What Is the NOPAIN Act? →.
NOPAIN Act at a glance
| Item | Detail |
|---|---|
| What it is | A separate Medicare payment for qualifying non-opioid pain management used during outpatient surgery |
| In effect | January 1, 2025 through December 31, 2027 |
| Settings | Hospital outpatient departments (HOPD) and ambulatory surgery centers (ASC) |
| Who’s paid | The facility — via its Part B MAC, not the DME MAC |
| Patient cost | Standard Medicare Part B 20% coinsurance |
| Qualifying cold + compression device | Game Ready GRPro 2.1 — effective January 1, 2026, at $1,997.16 |
The basics
What does NOPAIN stand for?
Non-Opioids Prevent Addiction in the Nation.[1]
What is the NOPAIN Act, in one sentence?
A Medicare rule that pays hospitals and ambulatory surgery centers separately for qualifying non-opioid pain management used during outpatient surgery, instead of burying its cost in the bundled procedure payment.[1-1]
When did it take effect, and when does it end?
Separate payment began January 1, 2025 and is currently set to run through December 31, 2027.[1-2]
Why was it passed?
To remove a payment disincentive: when a non-opioid option was bundled into the procedure payment, facilities absorbed its cost, which nudged toward opioids. The Act pays for the non-opioid option separately.[2]
What settings does it apply to?
Hospital outpatient departments (HOPD) and ambulatory surgery centers (ASC), for Medicare beneficiaries.[1-3]
Reimbursement
Who receives the payment?
The facility — paid by its Part B MAC, not the DME MAC — as an add-on on the facility claim.[2-1]
Does it reduce the surgical procedure payment?
No. The non-opioid payment is separate and apart from the procedure reimbursement.[2-2]
Does the patient owe anything?
The standard Medicare Part B 20% coinsurance applies to the separate payment.[2-3]
Is there an approved-procedure list?
No. CMS doesn’t tie qualifying products to specific procedures; a qualifying non-opioid product can be billed alongside covered outpatient procedures where it’s reasonable and necessary.[2-4]
How do facilities bill for it?
Using the appropriate HCPCS code per CMS guidance — and facilities should verify the correct code and eligibility with their MAC before submitting. Claims are subject to CMS/MAC audits.[2-5] (More: How NOPAIN Act Reimbursement Works →.)
Products & Game Ready
What qualifies under the NOPAIN Act?
Non-opioid drugs, biologics, and devices designated annually by CMS. Qualifying devices include the Game Ready GRPro 2.1 cold + compression system and the ON-Q and ambIT infusion pumps.[3] (Full list: NOPAIN Act Qualifying Products →.)
Is Game Ready covered under the NOPAIN Act?
Yes — the Game Ready GRPro 2.1 cryo-pneumatic compression system qualifies for separate Medicare payment effective January 1, 2026, at $1,997.16.[3-1]
Does the Act cover devices, or only drugs?
Both — drugs, biologics, and devices.[2-6]
Where’s the official list of qualifying products?
In the CMS OPPS/ASC Final Rule for the applicable year, updated annually.[1-4]
For patients
Does the NOPAIN Act mean my surgery pain relief is free?
No. It means Medicare pays your hospital or surgery center separately for qualifying non-opioid options used during outpatient surgery — so cost is less of a barrier to offering them. Your 20% coinsurance can still apply.[2-7]
Does it cover a cold therapy machine I use at home?
Not directly. The Act’s payment is for the outpatient surgical setting; home use follows separate rules, often a prescription or rental path.
What should I ask my surgeon?
Ask what the plan is to manage your pain and whether you can lean on non-opioid options like nerve blocks, non-opioid medications, and cold with compression.[4] (Guide: How to Ask Your Surgeon About Cold Compression →.)
Where WRS Group fits
WRS Group provides Game Ready cold + compression to surgical practices and patients, with 60,000 patients treated. Questions about a NOPAIN-qualified, non-opioid option for your setting or recovery? Reach out to WRS Group directly.
References
- CMS. CY 2025 / CY 2026 OPPS/ASC Final Rule. https://www.cms.gov/newsroom/fact-sheets/cy-2025-medicare-hospital-outpatient-prospective-payment-system-ambulatory-surgical-center-payment↩︎↩︎↩︎↩︎↩︎
- AAHKS. Summary — NOPAIN Act Implementation, Jan 7, 2025. https://www.aahks.org/wp-content/uploads/2025/01/AAHKS-Summary-No-Pain-Act-Implementation-01.07.25-1.pdf↩︎↩︎↩︎↩︎↩︎↩︎↩︎↩︎
- Avanos Medical. NOPAIN Act & Avanos. https://avanos.com/resources/nopain-act-and-avanos/ · PR Newswire, Dec 2025 (Game Ready added 2026).↩︎↩︎
- Bicket MC, et al. Prescription opioid analgesics commonly unused after surgery: a systematic review. JAMA Surgery. 2017;152(11):1066–1071.↩︎
Questions about a NOPAIN-qualified option?
WRS Group helps surgeons, ASC teams, and patients put a NOPAIN-qualified cold-and-compression option to work — tell us what you need and the right person will get back to you.