2026 OPPS Radiation Oncology: APCs 5621, 5622 and 5623

For most of the last decade a freestanding radiation oncology biller did not need to follow the hospital outpatient rule. In 2026 that changed. The CY 2026 OPPS and ASC final rule (CMS-1834-FC, released November 21, 2025, published in the Federal Register November 25, 2025, effective January 1, 2026) decided which ambulatory payment classification (APC) each of the three new treatment delivery codes belongs to, and the 2026 physician fee schedule then priced the freestanding technical payment for those codes from that hospital data. The 2026 OPPS radiation oncology placements are therefore the biggest single input to what a freestanding center is paid per fraction.

The office payment for 77407 now comes from Addendum B of a hospital rule. This post explains how to read it.

The headline numbers

Item	CY 2026 final
OPPS update	2.6 percent (3.3 percent market basket less 0.7 point productivity)
Conversion factor	$91.415 ($89.632 for hospitals that fail Hospital OQR reporting)
340B remedy offset	Stays at 0.5 percent of the conversion factor; the proposed 2 percent was not finalized, and CMS signaled a larger reduction for 2027

APC assignments for the delivery codes

The proposed rule (July 2025) put both IMRT-capable codes, 77407 and 77412, in APC 5622 at the same proposed rate. Commenters, the ACR among them, pointed out that the deleted IMRT codes 77385 and 77386 had both been assigned to APC 5623 before 2026. In the final rule CMS moved 77412 up a level and raised the Level 2 rate well above the proposal.

Code	Proposed APC (July 2025)	Proposed rate	Final APC	Final 2026 national rate
77402, treatment delivery Level 1	5621	$107.97	5621	$104.24
77407, treatment delivery Level 2	5622	$275.34	5622	$394.05
77412, treatment delivery Level 3	5622	$275.34	5623	$564.51

All figures are national unadjusted rates from the CMS addenda (status indicator S, paid separately); the hospital’s wage index adjusts them. The Level 3 APC rate itself was finalized slightly lower, $564.51 against a proposed $600.14, after 77412 was added to it.

Related codes are paid differently in the hospital. Image guidance 77387 carries status indicator N in Addendum B: packaged, never separately paid, which is why a hospital department does not report a 77387 line. The management codes 77427, 77431 and 77432 carry status B (physician services, billed on the professional claim), and 77435 is N.

Why this matters to a freestanding center

The CY 2026 physician fee schedule final rule (CMS-1832-F) finalized the use of “auditable, routinely updated hospital data” from OPPS to set relative rates for radiation treatment services paid under the fee schedule, instead of the practice expense inputs that normally come through the AMA RUC survey. In plain terms, CMS took the relationship among APCs 5621, 5622 and 5623 and scaled the freestanding technical payments for the three delivery codes to match.

The 2026 RVU file shows this. The amounts below are national, before geographic adjustment: total non-facility RVUs times the $33.4009 conversion factor, from the October 2026 release (RVU26D). They are not what any practice is paid; Medicare pays 80 percent, sequestration takes 2 percent, and the GPCI applies.

Code	OPPS APC rate (hospital)	PFS non-facility total RVUs	PFS national amount (freestanding)	Ratio
77402	$104.24	2.46	$82.17	79 percent
77407	$394.05	9.28	$309.96	79 percent
77412	$564.51	13.28	$443.56	79 percent

The ratio is the same on every line because the fee schedule amounts are set from the APC rates. If CMS moves a code to a different APC in a future rule, the freestanding rate changes too. That is why the ACR’s August 28, 2026 comment letter on the CY 2027 OPPS proposed rule, which asks CMS to move 77407 from APC 5622 (proposed 2027 rate $460.55) to APC 5623 (proposed $640.75), is a freestanding issue as much as a hospital one.

The superficial and orthovoltage codes

The new surface radiation therapy family was finalized as proposed.

Code	Service	2026 status indicator	APC	2026 national rate
77436	Surface RT treatment planning and simulation-aided field setting	Q1 (conditionally packaged)	5732	$38.16 when paid separately
77437	Surface RT delivery, 150 kV or less, per fraction	S	5621	$104.24
77438	Orthovoltage delivery, over 150 to 500 kV, per fraction	S	5621	$104.24
77439	Ultrasound image guidance for field placement, once per course	N (packaged)		No separate payment

A hospital is paid the same Level 1 amount for a superficial or orthovoltage fraction as for a 77402 fraction. Q1 on 77436 means it is packaged whenever another separately paid S, T or V service is on the same claim.

What the site-neutral policy does and does not cover

The rule’s new site-neutral policy extends the clinic-visit payment method to drug administration services in excepted off-campus provider-based departments: those APCs are paid at the physician fee schedule equivalent rate, which CMS estimates saves $290 million in 2026 ($220 million to Medicare, $70 million in beneficiary coinsurance). Radiation therapy is not included. An excepted off-campus department still bills 77402, 77407 and 77412 at full OPPS rates.

Nonexcepted off-campus departments are treated differently, as they were before. They used to bill the G6001 to G6017 series with modifier PN; with those codes deleted, CMS finalized that they bill 77402, 77407 and 77412 with PN, paid at the fee schedule technical component rate. The three-year phase-out of the inpatient-only list (285 procedures removed for 2026) does not affect radiation claims.

The low-volume brachytherapy APCs

When a clinical or brachytherapy APC has fewer than 100 single claims available for ratesetting, CMS’s universal low-volume APC policy sets the APC cost at the greatest of the geometric mean, arithmetic mean or median cost over up to four years of claims. For 2026 CMS finalized six brachytherapy APCs (and five clinical APCs) as low volume. Sources keep status indicator U, paid separately per source.

APC	Source	CY 2024 claims available	Final 2026 rate
2632	Iodine I-125 sodium iodide	1	$396.32
2635	Palladium-103, non-stranded, high activity	9	$106.75
2636	Palladium-103 linear, non-stranded	0	$89.40
2642	Cesium-131, stranded	49	$119.11
2643	Cesium-131, non-stranded	88	$99.80
2647	Iridium-192, non-stranded, non-HDR	3	$908.70

The other common codes stay in the same APCs: planning and dosimetry in APCs 5611 to 5613 ($137.32, $382.54 and $1,414.11; 77301 and 77295 are in 5613), special treatment procedure 77470 in 5623 alongside 77412, and SBRT delivery 77373 in APC 5626 at $1,826.78.

What to do now

Hospital departments: load the 2026 APC rates from Addendum B, not from a percentage applied to 2025, since 77407 and 77412 have no 2025 equivalent.
Freestanding centers: when you reconcile 77407 or 77412 allowed amounts, compare against the APC levels as well as the RVU file. A payer that pays “a percentage of Medicare” for the technical component is now, indirectly, paying a percentage of an APC.
Both: get the Level 3 documentation (active motion management, multiple isocenters, mixed photon and electron fields, total skin electrons) into the chart before the claim is sent. The gap between 5622 and 5623 is $170.46 per fraction in the hospital and about $134 per fraction nationally in the office.
Off-campus departments: confirm whether each location is excepted. Nonexcepted sites bill the delivery codes with PN at the fee schedule technical rate.
Multi-site practices: Iridium Suite’s site-of-service billing (Facility Track) selects the global, professional or technical component from the treatment location, so a department and a freestanding vault in the same practice produce the right component on each line; see the claim scrubber.
Watch November 2026. The CY 2027 OPPS final rule will say whether 77407 stays in APC 5622. If it moves, the freestanding rate changes too.

The 2026 OPPS final rule for radiation oncology: where 77402, 77407 and 77412 landed in the APCs, and why freestanding billers now read the hospital rule