Radiation oncology rule tracker: proposed versus final, 2026 and 2027
A proposed rule shows what CMS plans to do; the final rule sets the rates you load. This radiation oncology final rule tracker puts the two side by side for the items a radiation oncology biller actually prices from: the conversion factor, the three treatment delivery codes, image guidance, the superficial codes, the efficiency adjustment, planning and management, proton and brachytherapy, telehealth and supervision, and the MIPS threshold. The page is updated when each final rule publishes. The CY 2027 final column was filled in from the final rules released November 4, 2026.
Figures are national and unadjusted. Physician fee schedule amounts are total non-facility RVUs times the non-QP conversion factor, before the geographic adjustment, before the 80 percent Medicare share and before the 2 percent sequester. OPPS amounts are the national APC rate from Addendum B. None of them is what a given practice will be paid.
If you only have time for one row, read the delivery codes: it is the row where the 2026 proposal and the 2026 final rule differed most, and the row the 2027 final rule changed most.
CY 2026: proposed (July 2025) versus final (October and November 2025)
The CY 2026 physician fee schedule proposed rule (CMS-1832-P) went on display July 14, 2025 with comments due September 12, 2025; the final rule (CMS-1832-F) went on display October 31, 2025 and was published November 5, 2025. The CY 2026 OPPS proposed rule (CMS-1834-P) was released July 15, 2025; the final rule (CMS-1834-FC) was released November 21, 2025. Both took effect January 1, 2026.
| Item | Proposed | Final | Change | Source |
|---|---|---|---|---|
| PFS conversion factor, QP | $33.59 ($33.5875) | $33.57 ($33.5675), up 3.77 percent from $32.35 | Down $0.02 from proposal | CMS PFS proposed and final fact sheets |
| PFS conversion factor, non-QP | $33.42 ($33.4209) | $33.40 ($33.4009), up 3.26 percent from $32.35 | Down $0.02 from proposal | CMS PFS proposed and final fact sheets |
| Efficiency adjustment | Negative 2.5 percent to work RVUs and intraservice time of non-time-based services | Finalized at negative 2.5 percent; E/M, care management, behavioral health, telehealth-list and maternity global codes exempt | No change | CMS PFS proposed and final fact sheets |
| OPPS data for radiation treatment services | Proposed to price radiation treatment services from hospital OPPS cost data | Finalized | No change | CMS PFS proposed and final fact sheets |
| Delivery codes 77402, 77407, 77412, PFS | ACRO estimated a cut of about 10 percent to treatment delivery | ACRO estimated the final cut at about 3.8 percent; final national non-facility amounts $82.17, $309.96, $443.56 (2.46, 9.28 and 13.28 RVUs at $33.4009) | Cut narrowed by about 6 points | ACRO statement, November 6, 2025; CMS RVU26D file (see the OPPS post) |
| 77402, OPPS | APC 5621, $107.97 | APC 5621, $104.24 | Down $3.73 | CMS 2026 NPRM and NFRM Addendum B (see the OPPS post) |
| 77407, OPPS | APC 5622, $275.34 | APC 5622, $394.05 | Up $118.71; same APC, higher rate | Same |
| 77412, OPPS | APC 5622, $275.34 | APC 5623, $564.51 (APC 5623 itself was proposed at $600.14) | Moved up one APC; up $289.17 | Same |
| 77387 image guidance | RUC-surveyed work RVU 0.70 (down from 0.85) | Work RVU 0.68 after the efficiency adjustment; professional component only, technical component status B (bundled) | Down 0.02 | Practical Radiation Oncology article (PMC) |
| Superficial codes 77436 to 77439 | New family proposed; 77437 and 77438 in APC 5621 | Finalized as proposed: 77437 and 77438 in APC 5621 at $104.24; 77436 Q1 in APC 5732 ($38.16 when paid separately); 77439 packaged (status N) | No change in placement | CMS 2026 Addenda (see the OPPS post) |
| Planning and management (facility indirect PE) | Proposed to recognize greater indirect costs in office settings than facility settings | Finalized: facility indirect PE allocated on work RVUs set at half the non-facility amount; ACRO estimated non-delivery radiation oncology codes up about 5.2 percent | No change | CMS PFS fact sheets; ASH summary; ACRO statement |
| Proton beam delivery | Not tracked in this version | Not tracked in this version | ||
| Brachytherapy APCs | Low-volume brachytherapy APCs proposed under the universal low-volume policy | Six brachytherapy APCs finalized as low volume (2632, 2635, 2636, 2642, 2643, 2647); sources keep status U | Count as proposed not confirmed | CMS 2026 Addendum A; ACR HOPPS summary (see the OPPS post) |
| Telehealth and supervision | Permanent virtual direct supervision by real-time audio and video (not audio-only), excluding 010 and 090 global codes; provisional/permanent telehealth list distinction removed; frequency limits removed | All finalized as proposed | No change | CMS PFS proposed and final fact sheets |
| MIPS performance threshold | 75 points for the 2026 performance year | 75 points, held through the CY 2028 performance period (2030 payment year) | No change | CMS 2026 QPP final rule fact sheet |
| OPPS update | 2.4 percent (3.2 percent market basket less 0.8 point productivity) | 2.6 percent (3.3 percent market basket less 0.7 point productivity); conversion factor $91.415 | Up 0.2 point | CMS OPPS proposed and final fact sheets; ACR summary |
| 340B remedy offset | Raise from 0.5 percent to 2 percent of non-drug payments | Not finalized; stays 0.5 percent for 2026 | Dropped | CMS OPPS fact sheets |
The pattern of 2026: the fee schedule finalized almost exactly what it proposed, while the hospital rule moved substantially on the delivery codes after commenters pointed out that the deleted IMRT codes 77385 and 77386 had both been in APC 5623. Because CMS now prices freestanding delivery from the APC structure, that hospital-side move is also why the ACRO estimate of the freestanding cut narrowed between July and October.
CY 2027: proposed (July 2026) versus final (November 2026)
The CY 2027 physician fee schedule proposed rule (CMS-1848-P) went on display July 14, 2026, was published July 16, 2026, and closed to comments September 14, 2026. The CY 2027 OPPS proposed rule (CMS-1850-P) was released July 2, 2026, published July 7, 2026, and closed to comments August 31, 2026. Both final rules (CMS-1848-F and CMS-1850-F) were released November 4, 2026 and take effect January 1, 2027.
| Item | Proposed | Final | Change | Source |
|---|---|---|---|---|
| PFS conversion factor, QP | $33.17, down $0.40 (1.19 percent) from $33.57 | $32.95, down $0.62 (1.83 percent) | Down $0.22 from proposal | CMS CY 2027 PFS proposed and final fact sheets |
| PFS conversion factor, non-QP | $32.84, down $0.56 (1.68 percent) from $33.40; the one-year 2.5 percent increase expires | $32.63, down $0.77 (2.31 percent) | Down $0.21 from proposal | Same |
| Efficiency adjustment | Not mentioned in the CMS fact sheet | Not mentioned in the CMS fact sheet | ||
| Delivery codes 77402, 77407, 77412, PFS | Recalibrated after 77412 came in at about 18 percent of 2026 delivery volume against the 35 percent assumed; Radiation Business Solutions reported about +19, +10 and +8 percent | 2.98, 10.43 and 14.52 RVUs: $97.24, $340.33 and $473.79 at $32.63 (+18.3, +9.8 and +6.8 percent from 2026, conversion factor included) | Close to the proposal | CMS-1848-F Addendum B; RVU26D |
| 77402, OPPS | About +26 percent (RBS) | APC 5621, $130.01 (2026: $104.24) | Up 24.7 percent | CY 2027 final OPPS Addendum B |
| 77407, OPPS | APC 5622 at $460.55; the ACR asked CMS to move it to APC 5623 | Moved to APC 5623, $535.88 (2026: APC 5622, $394.05) | Moved up one APC; up 36.0 percent | Same; ACR comment letter, August 28, 2026 |
| 77412, OPPS | APC 5623 at $640.75 | APC 5623, $535.88 (2026: $564.51) | Down 5.1 percent from 2026; $104.87 below the proposal | Same |
| 77387 image guidance | No code-specific change reported | 1.08 RVUs, $35.24 (2026: 1.09, $36.41) | Down 3.2 percent | CMS-1848-F Addendum B |
| Superficial codes 77436 to 77439 | No code-specific change reported | Not checked in this update | ||
| Planning and management | Average practice expense RVU reduction of about 4.9 percent (RBS); a “PE stabilizer” replaces the anchor to old PE-per-hour data | PE stabilizer finalized; planning, simulation and management amounts down about 4 to 7 percent at $32.63 (77301 $1,833.81, 77427 $186.97) | As proposed | CMS final fact sheet; Addendum B |
| Specialty impact (RVU changes only) | About +3 percent (Ventra, combined with interventional radiology) | Radiation oncology and radiation therapy centers +2 percent; non-facility +4, facility -2 | CMS-1848-F specialty impact file | |
| Proton beam delivery | National PFS pricing proposed (about $1,029.56 per RBS); OPPS up about 12 to 14 percent | PFS status C to A: 77520 $415.71, 77522 to 77525 $1,132.26; OPPS APC 5625 $1,465.20 (+14.8 percent), 77520 in APC 5623 at $535.88 | National pricing finalized | Addendum B (PFS and OPPS) |
| Brachytherapy APCs | Listed among OPPS services with proposed increases | APC 5624 (77770 to 77772) $789.68, up 11.0 percent from $711.56 | CY 2027 final OPPS Addendum B | |
| Modifier 25 visits with global procedures | Lower-paid service at 50 percent when a visit is billed the same day as a 0, 10 or 90-day global procedure | 80 percent, and only with 0-day global procedures | Narrowed | CMS final fact sheet |
| Telehealth and supervision | RHC and FQHC telecommunication visits payable through December 31, 2027 | Finalized | No change | CMS final fact sheet |
| MIPS | Traditional MIPS to sunset beginning with the 2029 performance period | Sunset beginning with the CY 2031 performance period; one specialty-specific core measure required from CY 2027 | Two years later than proposed | CMS final press release |
| OPPS update | 2.4 percent (3.2 percent market basket less 0.8 point productivity) | 2.3 percent (3.2 percent less 0.9 point) | Down 0.1 point | CMS CY 2027 OPPS final fact sheet |
| 340B | ASP minus 33.4 percent; remedy offset on non-drug payments from 0.5 to 3 percent | ASP minus 28 percent; offset raised to 2 percent until the $7.8 billion is recovered (projected CY 2031) | Smaller cut and offset | Same |
The 2027 answer to the 2026 question: CMS moved 77407 into APC 5623. Because APC 5623 now holds the high-volume 77407 as well as 77412, its rate fell, so the two codes pay the same $535.88 in the hospital. On the fee schedule the three delivery codes went up close to the proposal while the conversion factor fell more than proposed. For the full write-up and a worked course, see the 2027 Medicare final rules for radiation oncology.
What to do now
- Load the final 2027 rates. Use the final Addendum B now and the January RVU file when it is posted; rebuild the expected-payment table from RVUs and $32.63 or $32.95, not by applying a percentage to 2026.
- Hospital departments: update 77407 and 77412 together. Both pay $535.88; 77412 is lower than in 2026.
- Proton centers: switch from contractor amounts to the national RVUs for dates of service from January 1, 2027.
- Model the conversion factor and the code changes separately. The 2.31 percent drop affects every line; the delivery increases affect three codes.
- Count 2026 courses by delivery level so you know how much of the delivery increase applies to your practice. Iridium Suite’s CodePath feature holds each course’s planned encounters and codes against the treatment plan, which is where that count comes from; see CodePath.
- Re-read percent-of-Medicare contracts before January: payers that reprice from the 2027 file will move delivery up and planning down automatically; fixed-year contracts will not.
Further reading
- CMS fact sheet: CY 2026 Physician Fee Schedule proposed rule (CMS-1832-P)
- CMS fact sheet: CY 2026 Physician Fee Schedule final rule (CMS-1832-F)
- CMS fact sheet: CY 2026 OPPS and ASC proposed rule
- CMS fact sheet: CY 2026 OPPS and ASC final rule
- CMS fact sheet: CY 2027 Physician Fee Schedule proposed rule
- CMS fact sheet: CY 2027 OPPS and ASC proposed rule
- CMS: CMS-1848-P rule page, with the September 14, 2026 comment close
- CMS: CMS-1850-P rule page, with the proposed OPPS addenda
- CMS fact sheet: CY 2027 Physician Fee Schedule final rule
- CMS press release: CY 2027 Physician Fee Schedule final rule
- CMS: CMS-1848-F rule page, with Addendum B and the specialty impact file
- CMS fact sheet: CY 2027 OPPS and ASC final rule
- CMS: CMS-1850-FC rule page, with the final OPPS addenda
- ACR: comment letter on the CY 2027 OPPS proposed rule, August 28, 2026 (PDF)
- Radiation Business Solutions: 2027 proposed rules for radiation oncology, July 13, 2026
- ACRO statement on the 2026 Physician Fee Schedule final rule (via CURE Today)
- Practical Radiation Oncology (PMC): Making sense of the 2026 CMS radiation oncology treatment delivery codes
- CMS: 2026 Quality Payment Program final rule fact sheet and policy comparison table (PDF)
- HFMA: CY 2027 Physician Fee Schedule proposed rule summary, part III, Quality Payment Program (PDF)