2027 Physician Fee Schedule Radiation Oncology Proposals

The CY 2027 physician fee schedule radiation oncology practices have been waiting for proposes to restore part of the payment the 2026 delivery code change removed, and to offset some of that with cuts to other codes. CMS found that Level 3 delivery (77412) made up about 18 percent of 2026 treatment volume rather than the 35 percent it had assumed, and proposes raising all three delivery codes. In the same rule the conversion factor falls because the one-year 2.5 percent increase expires, and planning and management codes lose practice expense value. The hospital outpatient proposed rule moves the same delivery codes up by larger percentages.

These are proposals. The final rules are expected in early November 2026, so use every number here to see which way payment may move, not as a rate to load.

The two rules and their dates

	CY 2027 Physician Fee Schedule	CY 2027 OPPS and ASC
Rule number	CMS-1848-P	CMS-1850-P
Released	July 14, 2026	July 2, 2026
Comments close	September 14, 2026	August 31, 2026
Headline update	Conversion factor down 1.19 percent (QP) and 1.68 percent (non-QP)	+2.4 percent for hospitals meeting quality reporting

The conversion factor goes down

	2026	2027 proposed	Change
Qualifying APM participants	$33.57	$33.17	-$0.40 (-1.19%)
All other clinicians	$33.40	$32.84	-$0.56 (-1.68%)

The statutory updates of 0.75 percent (QP) and 0.25 percent (non-QP) remain, and CMS adds an estimated 0.53 percent for proposed work RVU changes, but the 2.50 percent one-year increase Congress provided for 2026 “will no longer be in effect for CY 2027.” Unless Congress acts again before January, every 2027 line is paid from a lower conversion factor.

The delivery codes go up

In the CY 2027 proposed rule CMS reported that utilization of 77412 was significantly lower than assumed when the 2026 rates were set: about 18 percent of treatment volume against the 35 percent assumption, with most delivery billed as 77407. Because the 2026 values were built on that mix, CMS proposes to recalibrate.

Code	Proposed 2027 change, physician fee schedule (Radiation Business Solutions)	Proposed 2027 change, OPPS (Radiation Business Solutions)
77402, Level 1	+19 percent	+26 percent
77407, Level 2	+10 percent	+17 percent
77412, Level 3	+8 percent	+14 percent

On the hospital side the proposed rule also raises proton delivery codes by roughly 12 to 14 percent, lists brachytherapy among services with proposed increases, and revises APC assignments and rates for biology-guided radiotherapy (BgRT) as claims data accumulate. ASTRO’s reading of the fee schedule percentages differs from the figures above, which may reflect total versus technical-only comparisons; see the reviewer notes.

What is cut to offset the increases

Planning and management codes. Radiation Business Solutions estimates an average practice expense RVU reduction of about 4.9 percent across the planning and management family, and reports proposed cuts to the professional payment for SBRT and SRS.
Practice expense methodology. CMS proposes to phase out the step that anchored each specialty’s total PE RVUs to 2007-or-earlier PE-per-hour data, replacing it with a “PE stabilizer that mitigates short term volatility without anchoring overall values to a specific point in time.” It also asks whether the facility versus nonfacility site-of-service differential remains appropriate, a question that matters to any freestanding center.
Net effect. Ventra Health’s summary gives CMS’s combined estimated impact for interventional radiology and radiation oncology as approximately +3 percent in total allowed charges. That is a specialty average; a center whose volume is mostly 77407 will see something different from one that does mostly planning-heavy SBRT.

Other proposals that affect radiation oncology billing

Traditional MIPS sunset. CMS proposes ending traditional MIPS beginning with the 2029 performance period and moving clinicians to MIPS Value Pathways, adding three MVPs (Diabetes, Hypertension, Hospital-Based Care) and a new core measure requirement for both traditional MIPS and MVP reporting, with a proposed small-practice exemption. There is still no radiation oncology MVP.
Site-neutral imaging. The OPPS rule would pay the fee schedule equivalent rate for imaging-without-contrast APCs furnished in excepted off-campus provider-based departments (rural sole community hospitals exempt), saving an estimated $260 million in the first year. Radiation therapy is not included.
340B. CMS proposes paying ASP minus 33.4 percent for 340B-acquired drugs, with the offsetting budget-neutral increase spread across non-drug services, and raising the 340B remedy offset on non-drug payments from 0.5 percent to 3 percent until the $7.8 billion is recovered, which CMS projects for 2029.
Prior authorization. The OPPS rule proposes prior authorization for eight additional botulinum toxin codes, not for radiation therapy.
Telehealth. CMS proposes conforming changes so the RHC and FQHC telehealth flexibilities extended by the Consolidated Appropriations Act, 2026 run through December 31, 2027.

Worked example: the same 20-fraction course under the proposal

A single-isocenter IMRT prostate course, 20 fractions, freestanding, non-QP physician.

Line	Units	Proposed direction for 2027
77407 delivery	20	Code value up about 10 percent (RBS); conversion factor down 1.68 percent
77387-26 image guidance	20	No code-specific change reported; conversion factor down 1.68 percent
77427 weekly management	4	Part of the management family with an average 4.9 percent PE RVU cut; conversion factor down 1.68 percent
77301 IMRT planning and dosimetry	per course	Part of the planning family with the same average cut; conversion factor down 1.68 percent

Twenty delivery lines rising by roughly 10 percent will outweigh one planning line falling by roughly 5 percent, so a course like this comes out ahead of 2026 if the proposals hold. A hospital department billing the same 20 lines of 77407 under OPPS sees a larger proposed increase (about 17 percent) on a 2.4 percent update. Neither recovers the full gap LUGPA estimated between 77407 and the 2025 IMRT codes, which was 10 to 20 percent.

What to do now

Do not load proposed rates. Wait for the final rules and the Addendum B file, then rebuild the 2027 expected-payment table from RVUs and the final conversion factor.
Count your 2026 courses by delivery level. The proposal rewards 77402 and 77407 volume most in percentage terms; your own mix shows whether the specialty average applies to you. Because Iridium Suite’s CodePath feature holds each course’s planned encounters and codes, that count is available from the plans your team already built; see CodePath.
Model the conversion factor separately. A 1.68 percent drop applies to every line; the code changes do not. Leadership will ask why the “increase” is smaller than the headline.
Re-read percent-of-Medicare contracts. Payers that reprice from the 2027 RVU file will raise delivery and lower planning automatically; contracts that froze 2026 rates will not.
Check MVP readiness for 2027 reporting, since the proposal sets an end date for traditional MIPS.
Watch for a year-end conversion factor increase from Congress and for any ROCR provision attached to it.

The 2027 Medicare proposed rules for radiation oncology: delivery code increases, planning cuts and a lower conversion factor