Radiation Oncology Telehealth 2026: 77427, Supervision, POS

Three separate decisions set the radiation oncology telehealth 2026 rules. Congress extended the pandemic-era Medicare telehealth flexibilities through December 31, 2027 in the Consolidated Appropriations Act, 2026 (Public Law 119-75, signed February 3, 2026). The CY 2026 physician fee schedule final rule made two things permanent that had been temporary: direct supervision through real-time audio and video, and a telehealth services list with no provisional tier. And the 2026 list itself keeps weekly treatment management (77427) as a telehealth service while leaving 77431, 77432 and 77435 off it, which means those three must be furnished in person.

If your practice had telehealth claims returned and resubmitted during the October 2025 and January 2026 lapses, the rest of 2026 should be steadier. Keep the dates below on your calendar.

The calendar

Date	What happened or happens	Source
October 1, 2025	Telehealth flexibilities lapsed when Congress did not act; CMS had MACs return a subset of telehealth claims (CARC 16, RARC M77)	CMS MLN Connects, November 21, 2025
November 12, 2025	Public Law 119-37 restored the flexibilities retroactively, October 1, 2025 through January 30, 2026; returned claims became payable and could be resubmitted	CMS MLN Connects, November 21, 2025
February 3, 2026	Public Law 119-75 (H.R. 7148, Consolidated Appropriations Act, 2026) signed; section 6209 replaces “ending January 30, 2026” with “ending December 31, 2027” in section 1834(m) of the Social Security Act	Enrolled bill text, govinfo.gov
December 31, 2027	Last day for: no geographic restriction and the home as an originating site; the expanded practitioner list (including PTs, OTs, SLPs and audiologists); FQHC and RHC distant-site billing; audio-only telehealth; telehealth hospice recertification	Section 6209(a) to (f); CMS Telehealth FAQ, October 8, 2026
January 1, 2027	Deadline for CMS to require codes or modifiers on telehealth furnished through a contracted virtual platform and on telehealth furnished incident to a practitioner’s service	Section 6209(g)
January 1, 2028	In-person requirement for mental health telehealth begins; most other patients must again be in a rural medical facility	Section 6209(d); CMS Telehealth FAQ

Because the statute struck the January 30 end date and inserted December 31, 2027, the statute treats the authority as continuous. CMS’s October 2026 FAQ simply says beneficiaries can receive Medicare telehealth services anywhere in the United States “through December 31, 2027.”

What the 2026 fee schedule rule made permanent

The CY 2026 physician fee schedule final rule (CMS-1832-F) finalized telehealth policies that no longer depend on Congress.

Policy	2026 final rule
Telehealth services list	The provisional and permanent distinction is removed; every service added is permanent, and CMS reviews only whether the service can be furnished through interactive audio-video technology
Direct supervision	The supervising physician or practitioner may be present through real-time audio and video (not audio-only) for services that require direct supervision and do not carry a 010 or 090 global surgery indicator: incident-to services (42 CFR 410.26), diagnostic tests (410.32), pulmonary and cardiac rehabilitation, and certain hospital outpatient services (410.27)
Frequency limits	Removed for subsequent inpatient and nursing facility visits and critical care consultations
Teaching physicians	Virtual presence allowed in all teaching settings, only when the service itself is furnished as telehealth

The supervision change matters most to a freestanding center. Treatment delivery billed by the practice is furnished under the radiation oncologist’s direct supervision, the 2026 delivery codes 77402, 77407 and 77412 carry an XXX global indicator rather than 010 or 090, and the physician’s real-time audio and video presence now satisfies the requirement without a renewal date. Audio-only does not qualify. State law, accreditation and payer contracts may still require more.

77427 is on the list; 77431, 77432 and 77435 are not

The Medicare telehealth services list names the services payable under the fee schedule when furnished by telehealth. A service that is not on the list must be furnished in person to be paid.

Code	Service	On the CY 2026 list	Consequence
77427	Radiation treatment management, five fractions	Yes (“Maintain”)	May be furnished by interactive audio and video; POS 02 or 10
77431	Management of a course of one or two fractions	No	In person
77432	Stereotactic radiosurgery management	No	In person
77435	Stereotactic body radiation therapy management	No	In person

Two cautions on 77427. First, CMS’s general rule from 2025 allows audio-only in place of video only when the patient is at home and cannot, or does not consent to, use video and the practitioner is capable of video; treat a telehealth 77427 as a video service and document the exception if you ever rely on it. Second, a 77427 encounter furnished by telehealth is excluded from the radiation therapy denominator of MIPS quality measure 143 (pain intensity quantified), which counts only face-to-face management encounters. Reporting 77427 by telehealth is allowed, but it changes your quality numbers.

POS 02, POS 10 and modifier 95

Element	Medicare rule	Effect on payment
POS 10	Telehealth provided in the patient’s home (a private residence, not a hospital or other facility)	Paid at the non-facility fee schedule rate since January 1, 2024
POS 02	Telehealth provided other than in the patient’s home	CMS states the non-facility rate for the home only
Modifier 95	Required by CMS on institutional claims for outpatient therapy furnished by hospital-employed PTs, OTs and SLPs via telehealth	Identifies the telehealth service on the facility claim
Q3014	Originating site facility fee, $31.85 for 2026	Paid to the originating site, not the distant practitioner

For a professional claim, Medicare identifies telehealth from the place of service code rather than a modifier. Many commercial and Medicare Advantage payers still want modifier 95 on the professional line, and some reject POS 10; follow the payer’s current policy, and expect new federal modifier requirements for platform-based and incident-to telehealth by January 1, 2027 under section 6209(g).

Worked example: one course, one remote week

A freestanding center treats a 25-fraction prostate course. The radiation oncologist sees the patient in the department in weeks one, two, four and five. In week three the physician is at a second site and conducts the weekly management encounter by video with the patient at home.

Week	Fractions	Management encounter	Billing
1, 2, 4, 5	20	In person	77427, 1 unit each week, POS 11
3	11 to 15	Video, patient at home	77427, 1 unit, POS 10; excluded from measure 143’s radiation denominator (M1426)

Five units of 77427 in total, the same as a fully in-person course. The delivery lines are unaffected: 77407 is not a telehealth service, and the physician’s supervision of delivery in week three is handled by real-time audio and video under the permanent direct supervision definition, not by the telehealth list. Had this been a five-fraction SBRT course, the management code would have been 77435, which is not on the list, and the encounter would have had to be in person.

What to do now

Scrub the management codes against the place of service. 77431, 77432 and 77435 with POS 02 or 10 should stop before submission. Iridium Suite’s claim scrubber warns when 77431, 77432 or 77435 is billed for a telehealth facility type; see the claim scrubber.
Check October 2025 to February 2026 telehealth claims. Claims returned with CARC 16 and RARC M77 during the fall 2025 lapse are payable and can be resubmitted; refund any patient charged for a now-payable telehealth service dated on or after October 1, 2025.
Write the supervision workflow down. If a physician supervises delivery from another site by audio and video, the policy, the technology and the log should exist before a MAC or payer asks.
Set POS by patient location, not physician location. POS 10 when the patient is at home, POS 02 elsewhere.
Keep a payer grid for modifier 95, since Medicare does not need it on professional claims and many other payers do.
Plan for December 31, 2027. Follow-up visits at home without a rural restriction end then unless Congress acts again.

Telehealth and supervision in 2026 for radiation oncology: 77427 is on the list, 77431, 77432 and 77435 are not