CMS Releases 2026 Proposed Rules for MPFS and HOPPS: What It Means for Radiation Oncology
Earlier this month, CMS released the 2026 Proposed Rules for both the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS), introducing several impactful changes for radiation oncology providers. Here’s what you need to know:
Medicare Physician Fee Schedule (MPFS):
CMS is proposing substantial structural changes to how radiation oncology services are reimbursed in the freestanding setting.
Key Proposals Include:
- Code Modernization: CMS proposes deleting 17 G-codes and adopting new CPT codes for treatment delivery and image guidance. IMRT delivery codes (77385, 77386) will be deleted and absorbed into revised codes 77407 and 77412.
- Image Guidance: Technical component billing for image guidance (77014, G6002, etc.) will no longer be allowed. Physicians must use 77387-26 for all types of guidance.
- Conversion Factors: Slight increases are proposed — $32.7365 for APM participants and $32.5765 for non-participants.
- Superficial Radiation Therapy: New codes will replace existing ones, including updated descriptors for treatment delivery and image guidance.
- Telehealth: CPT 77427 (weekly treatment management) is proposed to be permanently added to the Medicare Telehealth List.
- Practice Expense Updates: CMS will use HOPPS data to weight Practice Expense RVUs for treatment delivery codes — aiming to align PFS costs with OPPS data.
- Proton Beam Therapy: CMS is evaluating national pricing and seeking stakeholder input.
Hospital Outpatient Prospective Payment System (HOPPS):
Changes under the proposed HOPPS rule are more moderate but still relevant.
Key Highlights:
- Payment Rate Update: Hospitals meeting quality reporting requirements will see a 2.4% net increase in OPPS payment rates.
- APC Assignments: No changes proposed for CPT 77412; it remains in APC 5622, despite CMS’s proposal to revalue it differently under MPFS.
- BgRT: Revised APC assignments for G0562 and G0563, with CY 2026 payment rates set at $1,250.50 and $3,750.50 respectively.
- Non-Excepted Off-Campus PBDs: CMS proposes deleting G-codes used by these sites and requiring them to bill with revised CPT codes (77402, 77407, 77412), using the “PN” modifier.
Next Steps:
We encourage practices to review these changes carefully, as they could significantly affect operations and reimbursement strategies — especially for freestanding centers. CMS is accepting comments through September 12, 2025 (MPFS) and September 15, 2025 (HOPPS).
Fill out the form on this page to download the full summaries!
Have questions? We’re here to help. Contact Radiation Business Solutions for more information or assistance navigating these proposed updates.
