Professional-only billing for hospital-based radiation oncologists in 2026: the claim, line by line
Hospital based radiation oncology billing splits one course of treatment across two claims. The hospital bills the technical side on its outpatient claim and is paid under the Outpatient Prospective Payment System (OPPS). The radiation oncologist, whether employed by the hospital or contracted to it, bills only the professional component on the CMS-1500 or 837P and is paid under the physician fee schedule. The Medicare Claims Processing Manual puts the rule in two sentences: the MAC pays the physician for the professional component of radiology services “in all settings,” and “may not pay for the technical component (TC) of radiology services furnished to hospital patients.” Every line on the physician’s claim must follow that rule.
If you have had a hospital-based claim come back with half its lines denied as bundled or not payable, this article is for you. The rules are consistent once they are laid out in one place.
Place of service: 22 or 19
Place of service 22 is “a portion of a hospital’s main campus” that provides outpatient diagnostic, therapeutic and rehabilitation services. POS 19 is the same thing in an off-campus provider-based department. Both show the payer that a facility pays the equipment and staff cost, so the fee schedule pays the physician the facility rate. For a new patient visit 99204 that is 3.50 total RVUs in 2026 against 5.31 in an office. For the radiation codes that are already professional-only (77263, 77427) or billed with modifier 26, the facility and non-facility totals in the CMS file are identical, so POS 22 or 19 does not reduce the payment. It still has to match the department, because a procedure or modifier that disagrees with the place of service denies with CARC 5.
The professional claim for a 20-fraction IMRT course
Single isocenter, daily image guidance, no motion management, so the hospital’s delivery code is 77407. The physician’s claim looks like this. PC/TC indicators and RVUs are from the CMS RVU26D file (October 2026 release); amounts are RVU times the 2026 conversion factor of 33.4009, national, before geographic adjustment, and illustrative.
| Line | Code | Units | PC/TC indicator | RVU total | National amount, each |
|---|---|---|---|---|---|
| Initial visit, decision to treat | 99204 (99205 if the level supports it) | 1 | 0, physician service | 3.50 facility | 116.90 |
| Clinical treatment planning, complex | 77263 | 1 | 2, professional only, no modifier | 5.04 | 168.34 |
| IMRT plan | 77301-26 | 1 | 1, split code | 12.55 | 419.18 |
| MLC devices for IMRT | 77338-26 | 1 per IMRT plan | 1 | 6.74 | 225.12 |
| Basic dosimetry calculation | 77300-26 | 4 (illustrative; MUE is 10 per date) | 1 | 0.98 | 32.73 |
| Image guidance, professional | 77387-26 | 20, one per fraction | 1; the TC row is status B | 1.09 | 36.41 |
| Weekly treatment management | 77427 | 4, one per five fractions | 2, professional only, no modifier | 5.85 | 195.40 |
Illustrative national total for the course: about 2,570.20 before geographic adjustment.
Four lines in that table need explanation.
The consult is an office visit. Medicare has not recognized the consultation codes since January 1, 2010; 99244 and 99245 carry status I in the 2026 RVU file. NCCI chapter 9 allows the initial E/M visit “at which time the decision to perform radiation therapy is made” with 99202 to 99215, or 99221 to 99223 for an inpatient, and no other E/M during the course. If the visit and 77263 fall on the same date and an NCCI edit applies, the manual says modifier 25 may be needed on the visit.
77387 is billable only with modifier 26. In RVU26D the technical row for 77387 is status B (bundled), and the global row shows “NA” for the facility setting. In POS 22 or 19 the only payable form is 77387-26, one per fraction, and the Q4 2026 MUE is 2 per date of service.
77427 counts fractions, not weeks. Chapter 13, section 70.1: a unit is five fractions “regardless of the actual time period”; three or four leftover fractions at the end are paid as a week, one or two are not. Twenty fractions is four units; 18 is also four; 22 is four. See CPT 77427.
No simulation line for IMRT. NCCI chapter 9 says the IMRT plan (77301) includes simulation-aided field settings and that 77280 to 77290 “shall not be reported separately” for IMRT, nor for field verification during the course.
What the hospital bills instead
The hospital’s outpatient claim carries the technical work. Status indicators are from the October 2026 OPPS Addendum B.
| Service | Hospital line | OPPS status | APC |
|---|---|---|---|
| Treatment delivery, Level 2 | 77407, 20 units | S, paid separately | 5622 |
| IMRT plan, technical | 77301 | S | 5613 |
| MLC devices | 77338 | S | 5612 |
| Dosimetry calculations | 77300 | S | 5611 |
| Special medical physics consultation | 77370 | S | 5611 |
| Continuing medical physics, per five fractions | 77336 | S | 5611 |
| Image guidance, technical | 77387 | N, packaged, no separate payment | |
| Port films | 77417 | N, packaged |
Addendum B lists 77263, 77427, 99204 and 99205 with status B, which confirms the same split from the hospital side: those are the physician’s lines, not the hospital’s. Chapter 13, section 70.5 adds that 77336 and 77370 “are technical services only codes,” so even a physics consult the physician requested is the hospital’s charge.
Lines a professional-only claim must never carry
- 77402, 77407 or 77412. PC/TC indicator 3, technical only, work RVU 0.00, and “NA” in the facility setting. The hospital bills delivery in every hospital-based arrangement.
- 77370 or 77336. Technical only (section 70.5 and PC/TC indicator 3).
- 77387 without 26, or 77387-TC. The TC is status B; the global is not payable in a facility.
- 77417. Status B everywhere since January 1, 2026; no one is paid for port films.
- Any TC modifier. The MAC may not pay a TC for a hospital patient.
- Modifier 26 on 77263 or 77427. PC/TC indicator 2 codes are professional-only by definition; the RVU file says “Modifiers 26 and TC cannot be used with these codes.”
- 77385, 77386, 77014, 77401 or any G6001 to G6017. Deleted for 2026; CARC 181, “procedure code was invalid on the date of service.”
- 77280 to 77290 during an IMRT course (NCCI chapter 9).
What to do now
- Agree on the split with the hospital in writing. One page: which entity bills which code for each course type, with the two tables above as the exhibit. Most hospital-based disputes are about 77387-26 and 77300-26, so settle those first.
- Set POS per department, 22 on campus and 19 off campus, and confirm the hospital’s claim says the same.
- Make 26 mandatory on 77301, 77338, 77300 and 77387, and impossible on 77263, 77427 and the E/M.
- Count 77427 from the treatment calendar and bill it as the units accrue rather than at the end of the course, so the first fraction’s date of service does not get close to the timely filing limit.
- Code the consult as 99202 to 99205, or 99221 to 99223 for an inpatient; never 99242 to 99245 for Medicare.
- Audit one paid remit a month for a 77407 or 77370 line on the physician claim, a 77387 line without 26, or a 77427 unit short of the fraction count.
- Let the system pick the component. Iridium Suite’s site-of-service billing (Facility Track) chooses the global, professional or technical component from the treatment location, so a course entered against a hospital department produces the 26 lines above and no delivery line; see the radiation oncology page.
Related: modifier 26 and TC, place of service codes, the 2026 delivery codes, radiation oncology claim denials and fixes.
Further reading
- Medicare Claims Processing Manual, chapter 13: Radiology Services (PDF), sections 20.1, 20.2.1, 70.1 and 70.5
- CMS PFS Relative Value Files, RVU26D (October 2026 release)
- CMS Place of Service code set
- NCCI Policy Manual for Medicare Services 2026, chapter 9 (PDF), section F, Radiation Oncology
- OPPS October 2026 Addendum B
- Medicare Claims Processing Manual, chapter 12 (PDF), section 30.6.10, consultation codes
- CMS fact sheet: CY 2026 Physician Fee Schedule final rule (CMS-1832-F)