Radiation oncology rule tracker: proposed versus final, 2026 and 2027

Medical Billing Blog·

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

radiation oncologyMedicarefee scheduleOPPS20262027