AI Contouring Billing: No Code Yet, and the Path to One

AI contouring billing does not exist as a separate line in 2026. Auto-segmentation software has FDA clearance, is installed in a growing share of planning systems, and saves real staff time, but no CPT or HCPCS code describes it and no payer pays for it apart from the planning codes the physician and dosimetrist already bill. The contours it produces are reviewed, edited and approved inside 77263, 77295, 77301 and related codes, and those codes are how the work is paid.

If your physicians ask why the new software has not produced a new charge, the answer is that no one has applied for a code yet, and the process takes years after an application. This post explains where things stand and what would have to happen.

What was cleared, and what the clearance says

GE HealthCare announced on June 4, 2026 that it had received FDA 510(k) clearance for MIM Contour ProtégéAI+ 2.0, an auto-contouring tool for radiation therapy planning, adding an MR brain model and an updated CT male pelvis model. The clearance “includes a Predetermined Change Control Plan (PCCP),” which the company described as “a framework for introducing future model updates and enhancements.” The release does not mention reimbursement, CPT codes or billing.

The FDA record behind it is K253270, decided March 27, 2026, for a device named Contour ProtégéAI+ from MIM Software Inc., product code QKB under 21 CFR 892.2050 (medical image management and processing system), flagged “Predetermined Change Control Plan Authorized.” The 510(k) summary says the submission’s subject device is “the upcoming 2.0.0 release,” and its indications for use describe “creation of contours using machine-learning algorithms for applications including, but not limited to, quantitative analysis, aiding adaptive therapy, aiding image registration, transferring contours to radiation therapy treatment planning systems,” while stating that the device “is not intended to detect or contour lesions” and that “appropriate image visualization software must be used to review and, if necessary, edit results.”

Two points for billers. First, the clearance is for normal-structure segmentation, not target delineation; the physician still draws or approves the target. Second, a PCCP means future anatomical models can be added without a new 510(k), so the tool can add models under the same clearance. The FDA’s own list of AI-enabled devices included entries dated as late as June 29, 2026 when we checked it, with radiology the most common review panel among the entries we read.

Why there is no code

A CPT code pays for a service that a clinician performs for a patient. Existing codes already cover contouring: it is part of the physician’s work in clinical treatment planning (77263, work RVU 3.06 in 2026) and in the dosimetry plans (77295, work RVU 4.18; 77301, work RVU 7.79), whose descriptors cover the plan, the dose-volume histograms and the structure definitions that drive them. Payer manuals list “contouring the target” among the components that distinguish 3D and IMRT planning from a simple isodose plan.

An AI tool that drafts the normal-structure contours changes who drafts the first version of the contours. It does not create a new service, and under the fee schedule’s logic it is a practice expense item, software the practice owns, not a separately reportable procedure. That is why eviCore’s and Evolent’s 2026 radiation oncology coding manuals, which cover the radiation oncology code range from planning through brachytherapy, contain no line for AI or auto-segmentation.

The path a code would have to take

Step	Who	What happens	Timing
1. Code change application	A specialty society, a manufacturer, a health system or another interested party	Applies to the CPT Editorial Panel, which “meets three times each year”; CPT Advisors from the specialties comment; the Panel approves, tables or rejects. The Panel “does not consider payment or coverage”	Agenda materials go out at least 60 days before each meeting
2a. Category III path	CPT Editorial Panel	A temporary code “for emerging technologies, services and procedures,” released three times a year. Category III codes carry no RVUs; in the 2026 fee schedule file nearly all of them are status C, contractor priced	The fastest way to get a code, but the slowest way to get paid
2b. Category I path	CPT Editorial Panel	A permanent code, which requires evidence of widespread use and clinical efficacy; approved changes “become effective on Jan. 1”	Panel approval to effective date is typically more than a year
3. Valuation	AMA/Specialty Society RVS Update Committee (RUC)	Staff issue a “Level of Interest” form; the specialty surveys at least 30 practicing physicians on time and intensity against reference codes; the RUC recommends work RVUs, times and practice expense inputs	RUC meets after each Panel meeting
4. Adoption	CMS	Publishes proposed values in the Physician Fee Schedule proposed rule (July) and final values in the final rule (early November), effective January 1; CMS may accept, modify or reject the RUC’s values and may assign a non-payable status	Annual cycle

The superficial radiation therapy codes that took effect this year are a current example of the timeline. CMS’s rule describes G6001 being flagged in October 2020, referred to CPT by the RUC in January 2021, created as four new codes by the CPT Editorial Panel in September 2024, surveyed for the January 2025 RUC meeting and paid from January 1, 2026. Even with a strong utilization case, that was more than five years from flag to payment. An AI contouring code would start today with no applicant, no survey data and an open question about whether it describes a physician service at all.

CMS uses one other method: it already prices radiation treatment delivery practice expense from hospital outpatient cost data rather than from RUC inputs. If AI planning software costs flow into hospital cost reports for the planning APCs, they can raise the practice expense of existing codes over time without any new code. That is slow and indirect, but it is the only payment mechanism that exists today.

How AI-assisted work fits existing codes

Code	What the physician or staff must still do	Where AI helps
77263, complex clinical treatment planning	Define the target volumes, dose, technique and critical structures; sign the plan	Organs at risk pre-drawn for review; the physician’s edit and approval is the billable work
77295 or 77301, 3D or IMRT plan	Dose-volume histograms for target and critical structures; physician and physicist approval	Faster structure sets mean faster plan turnaround; one plan per course either way
77300, basic dosimetry calculation	Verification calculations per field or arc	Unchanged
77370, special medical radiation physics consultation	A documented physics question the physician asked	Commissioning and QA of the AI model is operational cost, not a 77370
77387-26	Physician review of guidance images each treatment date	AI-assisted registration may speed review; the unit count does not change
Adaptive re-plans	A new data set, a documented change and a new plan	AI re-contouring at the console is adaptive planning, which has no code (see the adaptive article)

The first row is the compliance point. The FDA clearance requires that results be reviewed and, if necessary, edited. A planning note that shows the physician’s review and approval of every structure set is what supports 77263 and 77301 with or without AI; a note that shows contours imported and never reviewed is a problem with or without AI.

Worked example: the same prostate plan, twice

A 28-fraction IMRT prostate course in a freestanding center. Plan A was contoured by hand; Plan B used AI auto-segmentation for the bladder, rectum, femoral heads and bowel, reviewed and edited by the physician, who drew the target. Illustrative national amounts: 2026 RVUs times 33.4009, before geographic adjustment and sequestration.

Line	Plan A (manual)	Plan B (AI-assisted)
77263	1 unit, 168.34	1 unit, 168.34
77301	1 unit, 1,960.30	1 unit, 1,960.30
77338	1 unit, 474.96	1 unit, 474.96
77300	7 units, 469.98	7 units, 469.98
AI contouring	no line	no line
Planning total	3,073.58	3,073.58

The claims are identical. What differs is the dosimetrist’s time and how soon the patient starts treatment. That is the business case for the software.

What to do now

Do not create a charge for AI contouring, under 77470, 77399, 77499 or anything else, unless a payer has agreed in writing. Unlisted codes without a payer agreement are denied.
Document the physician’s review of AI-generated structures in the planning note; it is the work that 77263 and 77301 pay for.
Keep the model’s commissioning, validation and update records with your physics QA files; a PCCP means the model will change under the same clearance.
Measure the time saved per plan and per course and put it in the capital justification; the payment case for AI contouring in 2026 is throughput, not a code.
Watch the CPT Editorial Panel agendas and the PFS proposed rule each July for any AI-related radiation oncology code; the CY 2027 proposed rule discusses AI in general terms but says nothing about contouring or radiation oncology planning codes.
Iridium Suite imports planning and delivery charges from the Record & Verify system, so a practice adds an AI tool to its planning workflow without changing what is captured for billing; see the Record & Verify integration.

Can you bill for AI contouring? Not yet, and here is the path AI contouring billing would have to take