Ophthalmology billing
Ophthalmology Medical Billing and Revenue Cycle Management
Quilven is the outsourced billing office for independent ophthalmology groups. Collections in this specialty turn on four decisions: eye code or E/M for that visit, whether testing survives the edits, whether the injection and the drug both go out clean, and whether a same-day visit next to an injection would survive the review now aimed at this field. We take a percentage of collections. Where drug pass-through is most of the check, that percentage comes off professional work, not the vial.
Practices usually come in on one of these.
Section 3
Eye codes or E/M?
There is no house default. You pick per visit, against the note, the plan's allowables, and whether this patient already used the comprehensive-exam frequency. Practices that always pick one family lose money without a denial, because the other family would have paid and nobody ran the comparison.
Two families
Eye exams: 92002 and 92004 new, 92012 and 92014 established. Ending in 2 is intermediate. Ending in 4 is comprehensive.
Office E/M: 99202 to 99215. Since 2021 those levels sit on medical decision making or total time, not on a scored history and exam.
A 99204 is not a 92004 with a different number. They are graded on different work.
What the eye codes actually require
Comprehensive: all twelve exam elements unless age or trauma blocks one and that is written down, a comprehensive history, and start of a diagnostic and treatment program. That last piece is where plans downcode. Medication, further testing or treatment, a consult, lab, imaging, or a glasses or contact prescription can satisfy it.
Intermediate: expanded problem-focused history, intermediate exam, start of treatment.
How to choose without guessing
Neither family wins on every payer. Keep the fee schedules for your top plans and look at the visit types you actually do.
Eye codes often allow one comprehensive exam in twelve months. E/M usually does not. Sometimes the lower allowable is the correct claim because the higher one will fail frequency and land on the patient.
If nearly every established visit in your file is 92014, that is a mix question, not a style. Vendor estimates of the annual loss exist. We are not repeating them. The mechanism does not need a dollar figure to be worth an afternoon of pulling charts.
Auditors have scored eye-code notes with E/M rules. Keep the twelve-element list in the folder you hand them.
Two families, graded differently
Intermediate
Comprehensive
Intermediate
Comprehensive
By MDM or time
By MDM or time
Section 4 — free ophthalmology tool
Buy-and-bill margin calculator
Type your acquisition cost and your payment. It shows margin per injection, then what a percentage billing fee does if the fee sits on all collections versus collections after the drug is pulled out. No published ASP table. Your numbers only, so the page cannot go stale next quarter. Runs in your browser. There is nowhere to enter patient information and none is needed.
Illustration only. Not billing, legal, tax or clinical advice. Check the current schedule. Do not enter patient information. This tool runs entirely in your browser; nothing is sent anywhere.
Methodology
- Margin per shot = payment per dose minus acquisition cost per dose.
- Monthly margin = margin per shot times injections per month. Annual = monthly times 12.
- Fee on all collections = payment per dose times injections per month times fee percent divided by 100.
- Fee excluding drug = (payment minus cost) times injections per month times fee percent divided by 100.
- Fee as share of drug spread = fee per shot divided by margin per shot, times 100.
Worked example (illustrative)
Aflibercept (Eylea). Cost $1,850 per dose. Payment $2,060 per dose. 30 injections per month. Fee 5%.
Margin per shot: $210. Monthly margin: $6,300. Annual: $75,600.
Fee on all collections: $2,060 times 30 times 5% = $3,090 per month. That is 49% of the drug spread.
Fee excluding drug: $210 times 30 times 5% = $315 per month. That is 5% of the drug spread.
Same fee percent. Different base. One eats half the spread; the other takes a sliver. That is why the base matters more than the percent on a retina book.
Sources
- CMS ASP Regulations and Policy, Medicare Part B drug payment methodology.
- CMS biosimilar payment: ASP plus 6% of reference product ASP; temporary ASP plus 8% for qualifying biosimilars.
- ASPE and CMS guidance on biosimilar reimbursement and the limited window for the higher add-on.
This tool also lives at its own address: /tools/buy-and-bill-margin-calculator/.
Section 5
Vision plan says medical. Medical plan says routine.
Chief complaint, diagnosis and what you found decide the route. Preference and 'which pays more' do not. Refraction and a routine glasses exam go to the vision plan or the patient. Disease, injury or a symptom goes to the medical plan. Medicare does not pay exams done to prescribe or fit glasses, and it does not pay refraction.
Wrong both ways: a real medical exam dumped on a cheap vision benefit, or a refractive visit sent to medical and then denied, sometimes after the patient was told it was covered.
Same day: medical plan for the exam, vision plan for the refraction, coordination of benefits. Never both plans for the same line.
Collect refraction from the patient up front. Submitting 92015 to Medicare and then writing it off is working from the wrong end.
Map it by payer, not by visit
Some refractive-plan agreements treat the exam as prepaid routine care no matter the complaint. That cuts across the diagnosis-first rule. It is contract-specific. Map it by payer, not by visit.
Compliance review before this section publishes.
Section 6
Why the test denied
Usually one of three: same-day bundling, frequency, or an interpretation that is only a result.
Fundus photography and posterior-segment OCT are mutually exclusive under the national edits. Both on the same eye the same day pays only when necessity is real, a modifier is justified, and it is uncommon. Photography also bundles with extended ophthalmoscopy and ICG. Optic-nerve OCT and retina OCT are not both reported at one encounter.
Volume is watched. Intervals on retinal imaging change by plan and by diagnosis.
Where the descriptor includes interpretation and report, the report has to do work: the finding, comparison when there is a prior, and what it does to management. "Stable" and "normal" are treated as already paid inside the visit.
The order comes first. A protocol or screening test is not payable even if it finds disease.
If you own the camera and you read it, bill the global. Billing only 26 on your own machine gives away the technical half.
Why the test denied
Fundus photo + posterior OCT
Mutually exclusiveFundus photo + extended ophthalmoscopy
BundledFundus photo + ICG
BundledOptic-nerve OCT + retina OCT
Not both at one encounterGlobal on your own equipment
Bill globally, not 26 onlySection 7
Injections and the drug
67028 and the J- or Q-code travel together. Most failures are missing laterality, missing JW or JZ, or the drug denied as not reasonable and necessary, which takes the injection with it.
Laterality
RT, LT or 50 has to be on the injection. Without it the claim is returned unprocessed, not denied. Unprocessed work never hits your denial report. It sits in a rejection file. If injection volume and paid injection claims do not match, start there. One unit per eye per encounter. Two eyes on two days are two encounters.
Wastage
Single-dose container: JW if you discarded billable units, JZ if you discarded none. Always one of those two. JZ has been required since 1 July 2023. Since 1 October 2023 a single-dose claim with neither modifier is rejected. Groups that built JW and never added JZ still walk into that edit.
On the injection, every time
Right eye
Left eye
Bilateral
Always one of two, on single-dose
Discarded billable units
No discarded units
The drug sinks the procedure
A medical-necessity or step-therapy failure on the vial is a whole-claim failure.
Prior auth and step therapy
Commercial and many Medicare Advantage plans want authorization on the expensive agents and often want a documented Avastin failure first. Traditional Medicare does not step-therapy anti-VEGF. CMS has allowed Medicare Advantage plans to apply Part B step therapy since 2019. Do not tell a client that MA cannot do it. Commercial plans always could.
Compliance review on this section.
Section 8
The modifier 25 review, as of now
OIG report A-09-23-03014 (May 2025) looked at E/M billed with 25 on the same day as an eye injection. Audit window June 2022 through May 2023. Medicare paid $313 million for 3.3 million injections and $124 million for 1.4 million same-day visits with 25. Forty-two percent of injections carried that visit. Of 24 sampled visits, 22 did not support the modifier. OIG put up to about $124 million at risk and told CMS to clarify the rule, review and recover, and teach.
A nationwide SMRC review of established-patient eye visits with 25 next to injections followed. AAO has said an earlier SMRC pass found a much lower error rate than the OIG sample, and has argued against more audits until injection-specific guidance exists. CMS updated an MLN booklet in September 2025, then stripped the confusing language in June 2026 after specialty advocacy.
25 goes on the visit, not on 67028. The visit has to be significant, separately identifiable, and not just the decision to inject. Checking that the eye is ready for the shot you already planned is part of the shot.
If a visit rides along with almost every injection, that pattern is what reviewers pull. Keep billing real separate visits. Measure the share. A group that has never counted is in a worse seat than one that can explain the number.
Re-date this section whenever the review moves. Compliance review before publish.
Section 9
Cataract, premium lenses, co-management
Complex versus routine
66982 pays more and only when the note shows non-routine technique: pupil expansion, zonular support, a mature or dense lens, a paediatric case. A long, hard 66984 is still 66984. A high 66982 rate is an old audit flag. ASCRS: Medicare professional payment for 66984 in 2026 is $462.94, about 11 percent below 2025, from the efficiency adjustment and facility PE changes.
Premium IOLs
Medicare pays the cataract operation and the conventional lens amount. The patient pays only the identifiable refractive piece of a premium lens. She has to be able to choose a standard lens. Because that piece is statutorily excluded, the usual ABN is not the tool.
Co-management
When postop care moves to an optometrist, the surgeon bills 54 and the co-managing clinician bills 55 on the same code and diagnosis. The published split is about 80/20 and cannot exceed the global. Both offices keep a written transfer with dates and duties. Assumed and relinquished dates go on the claim.
Co-management split
A surgeon may not park every postop visit outside the practice as policy. OIG has said it will look at shops where the split always happens. Co-management is not for two clinicians in the same group. It is all or nothing on a combined case.
Comparative billing reports have gone to high co-management referrers, high 66982 users, and high early YAG billers. If you are an outlier, an explanation beats the extra line.
Compliance review on this section.
Section 10
Does a percentage of collections work on a retina book?
Not on the full base, and we would rather write that than take the account and hope nobody runs the math.
Anti-VEGF can be most of collections while you keep roughly ASP plus 6 percent, about 4.3 percent after the 2 percent sequester on the Medicare-paid share. A fee calculated on the whole remittance is a fee on money that passed through the practice. On a high-cost vial that fee can eat the spread, or exceed it.
Percentage pricing is fine for most of ophthalmology. It is a poor fit for drug pass-through.
What we do
For books where the vial distorts the base, we take the fee off professional collections, not the pass-through. That is a commercial commitment. If it is not how we will actually quote, this section has to be rewritten, not deleted.
Put your highest-volume drug in the calculator. Toggle the fee base. If a company quotes a percent without asking about drug mix, that is information.
Biosimilars are paid on their own ASP plus a percent of the reference product's ASP for a limited window. A cheaper vial can mean a smaller dollar add-on than the brand. That is why "cheaper for the plan" is not always cheaper for the practice that bought it.
Section 11
What we handle
Section 12
Free 48-hour AR audit
We start with the injection rejection queue and the eye-code versus E/M split. If it is clean we say so.
How many physicians?
Drug share of collections?
Employed ODs or co-managed postop?
You told us
not set physicians · Drug share: not set · Employed ODs / co-managed postop: not set
Section 13
Common questions
New or established?+
Three-year rule, same specialty and subspecialty in the group. Retina and glaucoma in one TIN can each still see the patient as new.
Injection unprocessed, not denied?+
Laterality almost every time. RT, LT or 50 has to be on 67028. Without it the claim is returned unprocessed, not denied, so it never hits your denial report. Volume versus paid claims is the first question worth asking.
Fundus photo and OCT same day?+
Rarely. National edits treat them as mutually exclusive. Routine pairing is a review item. Both on the same eye the same day pays only when necessity is real, a modifier is justified, and it is uncommon.
Both wastage modifiers?+
One or the other on every single-dose claim. JW if you discarded billable units, JZ if you discarded none. Neither means reject. JZ has been required since 1 July 2023, and since 1 October 2023 a single-dose claim with neither is rejected.
Does 25 keep you off an audit list?+
No. It asserts a separate visit. The note has to prove it. OIG's sample of 24 mostly did not: 22 did not support the modifier. The pattern of a visit on almost every injection is what reviewers pull.
OD takes postop?+
54 and 55, same code, written transfer, dates. Not routine for every case. Not inside one group. The published split is about 80/20 and cannot exceed the global. OIG has said it will look at shops where the split always happens.
Keep our biller?+
Yes. Charge capture and the people in the building stay. Submission, coding review, denials, AR, auth and credentialing can move.
Fee?+
Percent of collections after the audit. Drug-heavy books: pass-through out of the base, for the reasons in section 10. No setup, no platform fee, no minimum, 30 days' notice.
Section 14
Sources
- OIG Report A-09-23-03014, May 2025: Medicare payments for E/M services provided on the same day as eye injections
- CMS Calendar Year (CY) 2026 Medicare Physician Fee Schedule final rule (CMS-1832-F)
- CMS National Correct Coding Initiative (NCCI) Policy Manual
- CMS JW and JZ modifier billing guidelines (single-dose container drugs)
- American Academy of Ophthalmology: modifier 25 advocacy and resources
- American Academy of Ophthalmology: coding and reimbursement
- ASCRS: 2026 Medicare Physician Fee Schedule final rule, 66984 payment
- CMS ASP regulations and policy: Medicare Part B drug payment methodology
- CMS biosimilar payment: temporary increase and ASP reporting
- MGMA data reports: cost and revenue survey benchmarking