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 reads “pending” until then. Last checked September 30, 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 proposal is meant to correct.
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 (pending)
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. As of September 30, 2026 neither final rule had been published.
| Item | Proposed | Final | Change | Source |
|---|---|---|---|---|
| PFS conversion factor, QP | $33.17, down $0.40 (1.19 percent) from $33.57 | Pending | CMS CY 2027 PFS fact sheet | |
| PFS conversion factor, non-QP | $32.84, down $0.56 (1.68 percent) from $33.40; the one-year 2.5 percent increase expires | Pending | CMS CY 2027 PFS fact sheet | |
| Efficiency adjustment | Not mentioned in the CMS fact sheet | Pending | ||
| 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 reports about +19, +10 and +8 percent | Pending | Radiation Business Solutions, July 13, 2026 | |
| 77402, OPPS | About +26 percent (RBS); APC 5621 rate not yet confirmed | Pending | Radiation Business Solutions | |
| 77407, OPPS | APC 5622 at $460.55 (about +17 percent per RBS); ACR and ASTRO asked CMS to move it to APC 5623 | Pending | ACR comment letter, August 28, 2026; RBS | |
| 77412, OPPS | APC 5623 at $640.75 (about +14 percent per RBS) | Pending | ACR comment letter; RBS | |
| 77387 image guidance | No code-specific change reported | Pending | ||
| Superficial codes 77436 to 77439 | No code-specific change reported | Pending | ||
| Planning and management | Average practice expense RVU reduction of about 4.9 percent across planning and management (RBS); PE methodology moves to a “PE stabilizer” and CMS asks whether the facility versus non-facility differential remains appropriate | Pending | RBS; CMS CY 2027 PFS fact sheet | |
| Proton beam delivery | OPPS rates up about 12 to 14 percent, several delivery codes above $1,434; PFS freestanding delivery about $1,029.56 (RBS) | Pending | Radiation Business Solutions | |
| Brachytherapy APCs | Listed among OPPS services with proposed increases; no figures reported yet | Pending | Radiation Business Solutions | |
| Telehealth and supervision | RHC and FQHC telecommunication visits payable through December 31, 2027 to conform to Public Law 119-75; no supervision change reported | Pending | CMS CY 2027 PFS fact sheet | |
| MIPS performance threshold | 75 points, unchanged (previously finalized through the 2028 performance year); traditional MIPS proposed to sunset beginning with the 2029 performance period (2031 payment year) | Pending | HFMA QPP summary; MDinteractive | |
| OPPS update | 2.4 percent (3.2 percent market basket less 0.8 point productivity) | Pending | CMS CY 2027 OPPS fact sheet | |
| 340B | Pay 340B-acquired drugs at ASP minus 33.4 percent, budget neutral, with non-drug payments rising to offset | Pending | CMS CY 2027 OPPS fact sheet |
The main 2027 question is the same one the 2026 final rule settled in November: does 77407 stay in APC 5622? The ACR’s comment letter puts the difference at $460.55 versus $640.75 per fraction in the hospital. Because the freestanding technical rate follows the APC rates, a move would also change payment on every freestanding 77407 line.
What to do now
- Do not load proposed 2027 rates. Wait for the final Addendum B and the January RVU file, then rebuild the expected-payment table from RVUs and the final conversion factor.
- Read the final rules for one thing first: the APC assignment of 77407. Everything else in the delivery row follows from it.
- Model the conversion factor and the code changes separately. A 1.68 percent drop affects every line; the delivery increases affect three codes.
- Count 2026 courses by delivery level so you know whether the 18 percent Level 3 figure describes 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.
- Bookmark this page. It will be updated the week each final rule publishes.
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
- 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)