What Is the NOPAIN Act?

The NOPAIN Act (“Non-Opioids Prevent Addiction in the Nation”) gives hospitals and ambulatory surgery centers a separate Medicare payment when they use a qualifying non-opioid pain management product during outpatient surgery. Before the Act, the cost of that non-opioid option was buried inside the bundled procedure payment, so using it cost the facility money. Now Medicare pays for it separately — without reducing what the facility earns on the procedure. The provision runs January 1, 2025 through December 31, 2027.

If you run an ASC or a hospital outpatient department, that paragraph is the whole point. The rest of this page is for when you want to know exactly what qualifies, how the payment reaches you, and what it means for offering a non-opioid recovery plan.

Why the Act exists

Surgery is one of the most common ways a patient is first exposed to opioids. A widely cited review found that opioids are frequently left over and unused after surgery — a sign that prescriptions routinely exceed what patients actually need, and that the leftovers become a risk of their own.^[1]

The problem was never only about prescribing habits. Medicare’s payment design quietly discouraged the alternatives. When a non-opioid drug or device was folded into a single bundled payment for the procedure, the facility absorbed its cost — so the cheaper path was to reach for the opioid. The NOPAIN Act was written to remove that disincentive.

What the Act actually changes

The NOPAIN Act directs CMS to unbundle Medicare Part B payment for qualifying non-opioid treatments in two settings: the hospital outpatient department (HOPD) and the ambulatory surgery center (ASC).^[2]

In plain terms:

• The facility gets a separate, add-on payment for the qualifying non-opioid product, on top of the procedure payment.^[2-1]
• It does not reduce the procedure reimbursement. The non-opioid payment sits separate and apart from what the facility already earns on the surgery.^[3]
• The payment comes from the Part B MAC — the same contractor that handles the facility claim — not the DME MAC.^[3-1]
• The patient’s standard 20% coinsurance applies to the separate payment, like other Part B services.^[3-2]

This is a facility-side payment, tied to the outpatient surgical setting. It is not a statement about what a patient’s home rental is or isn’t covered for — a separate question with its own rules.

What qualifies

CMS designates the qualifying non-opioid drugs, biologics, and devices that are eligible for separate payment when they’re furnished in connection with a covered outpatient surgical service.^[3-3] A few things worth knowing:

• The product still has to meet standard Medicare coverage rules — it must be “reasonable and necessary” for the patient.^[3-4]
• There are no “approved procedure” lists tying a specific product to a specific surgery. CMS doesn’t restrict which covered outpatient procedure a qualifying product can be billed alongside.^[3-5]
• Facilities bill using the appropriate HCPCS code per CMS guidance, and should verify eligibility with their MAC before submitting. Claims are subject to CMS and MAC audits.^[3-6]

The list of qualifying products is set through the annual OPPS/ASC Final Rule and updated each year — so it grows over time as more non-opioid options are added.^[2-2]

Where cold and compression fits

The Act covers devices, not only drugs — which is what opened the door for non-opioid cold and compression systems used after orthopedic surgery. Cold and compression has a long track record of reducing swelling and pain after a procedure, and studies have linked it to lower opioid use in recovery.^[4][5]

As of January 1, 2026, the Game Ready GRPro 2.1 cryo-pneumatic compression pain management system meets the qualifying requirements for separate payment under the NOPAIN Act — joining the non-opioid options a facility can offer and be paid for separately.^[6] We cover exactly what that means for a practice in Game Ready and the NOPAIN Act →.

The window matters

The separate-payment provision is temporary — it runs through December 31, 2027.^[2-3] For a facility weighing whether to build a non-opioid pathway into its outpatient recovery protocol, the reimbursement support is here now and on a clock. Practices that stand up the workflow early get the most out of it.

Where WRS Group fits

WRS Group provides Game Ready cold and compression to surgical practices and their patients, with 60,000 patients treated. If your practice or ASC wants help understanding how a NOPAIN-qualified, non-opioid recovery option fits your workflow, you can reach out to WRS Group directly.

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Frequently asked questions

What does NOPAIN stand for?
Non-Opioids Prevent Addiction in the Nation. The Act gives hospitals and ASCs separate Medicare payment for qualifying non-opioid pain management used during outpatient surgery.^[2-4]

When did the NOPAIN Act take effect, and when does it end?
Separate payment began January 1, 2025 and is currently set to run through December 31, 2027.^[2-5]

Does the NOPAIN Act reduce the payment for the surgical procedure?
No. The non-opioid payment is an add-on, separate and apart from the procedure reimbursement.^[3-7]

What settings does it apply to?
Hospital outpatient departments (HOPD) and ambulatory surgery centers (ASC), for Medicare beneficiaries.^[2-6]

Does it cover devices, or only drugs?
Both. CMS designates qualifying non-opioid drugs, biologics, and devices for separate payment.^[3-8]

Is Game Ready included?
Yes — the Game Ready GRPro 2.1 cryo-pneumatic compression system qualifies for separate payment beginning January 1, 2026.^[6-1]

Does the patient pay anything?
The standard Medicare Part B 20% coinsurance applies to the separate payment.^[3-9]

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References

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1. Bicket MC, Long JJ, Pronovost PJ, Alexander GC, Wu CL. Prescription opioid analgesics commonly unused after surgery: a systematic review. JAMA Surgery. 2017;152(11):1066–1071.↩︎
2. Centers for Medicare & Medicaid Services. CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS-1809-FC). https://www.cms.gov/newsroom/fact-sheets/cy-2025-medicare-hospital-outpatient-prospective-payment-system-ambulatory-surgical-center-payment↩︎↩︎↩︎↩︎↩︎↩︎↩︎
3. American Association of Hip and Knee Surgeons (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↩︎↩︎↩︎↩︎↩︎↩︎↩︎↩︎↩︎↩︎
4. Block JE. Cold and compression in the management of musculoskeletal injuries and orthopedic operative procedures: a narrative review. Open Access Journal of Sports Medicine. 2010;1:105–113. PMID: 24198548.↩︎
5. Thijs E, Schotanus MGM, Bemelmans YFL, Kort NP. Reduced opiate use after total knee arthroplasty using computer-assisted cryotherapy. Knee Surgery, Sports Traumatology, Arthroscopy. 2019;27(4):1204–1212. PMID: 29725749.↩︎
6. Avanos Medical. NOPAIN Act & Avanos. https://avanos.com/resources/nopain-act-and-avanos/ · and: “CMS Maintains NOPAIN Act Eligibility for ON-Q and AmbIT Infusion Pumps; Adds Game Ready in 2026,” PR Newswire, Dec 2025.↩︎↩︎