CMS has released the 2027 Proposed Rules for both the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (OPPS), introducing several important changes that could impact radiation oncology providers across both freestanding and hospital-based settings. Here’s what you need to know:
Medicare Physician Fee Schedule (MPFS)
For CY 2027, CMS estimates a positive impact of 3% for radiation oncology overall, including a projected 5% increase for freestanding centers and a 1% decrease for facility-based providers. However, the actual financial impact will vary significantly based on each practice’s service mix, treatment utilization, site of care, and operational profile.
While several radiation treatment delivery codes are proposed for increases, many essential planning, management, and other non-treatment services are proposed for reductions. The proposed conversion factor is also decreasing for both APM and non-APM providers.
Key Proposals Include:
Treatment Delivery Revaluation: CMS is proposing significant increases to the Practice Expense (PE) Relative Value Units (RVUs) for the three primary radiation treatment delivery codes based on updated claims data and actual utilization patterns:
- CPT 77402: +19% proposed rate increase
- CPT 77407: +10% proposed rate increase
- CPT 77412: +8% proposed rate increase
CMS found that utilization of CPT 77412 was significantly lower than originally projected, accounting for approximately 18% of the treatment mix compared with the 35% utilization assumed when establishing the 2026 rates. CMS is proposing to revalue CPT codes 77402, 77407, and 77412 to better reflect observed utilization.
Conversion Factor: Proposed conversion factors would decrease for both provider categories:
- Non-APM: $32.8409, a 1.68% decrease
- APM: $33.1693, a 1.19% decrease
Non-Treatment Services: Most radiation oncology planning, management, physics, and related non-treatment services are proposed for PE RVU reductions. The impact varies by setting, with many hospital-based services seeing reductions of approximately 1% to 2.5% and freestanding services seeing reductions of approximately 1.5% to 5%.
SBRT and SRS: Reimbursement for SBRT treatment codes is projected to decrease by approximately 6.5%, despite CMS proposing significant payment increases for these services under the OPPS.
Practice-Level Impact: The proposed changes will affect practices differently. Most professional HOPD practices could see a 3% to 3.5% decrease in Medicare and Medicare Advantage reimbursement, while many freestanding providers could see an increase of approximately 2% to 3%. The impact will depend heavily on treatment-level utilization and the mix of planning, image guidance, and management services.
Proton Therapy: CMS continues to explore ways to establish national payment rates for proton therapy. While the proposed rule does not establish a new reimbursement methodology for proton therapy delivery codes, CMS is proposing to develop Practice Expense RVUs using allowed charges and OPPS APC relative weights. Proton therapy providers should continue to monitor future rulemaking as CMS evaluates the valuation and payment methodology for these services.
Hospital Outpatient Prospective Payment System (OPPS)
The 2027 proposed OPPS rule includes several notable changes for hospital outpatient departments and other providers of radiation oncology services. Overall, the proposed changes are favorable for many radiation oncology treatment delivery services, with several codes receiving double-digit proposed payment increases.
Key Highlights:
Payment Rate Update: Hospitals that meet applicable quality reporting requirements would receive a proposed 2.4% increase in OPPS payment rates for CY 2027.
Radiation Oncology Payment Increases: CMS is proposing meaningful payment increases across many radiation oncology services, including treatment planning, treatment delivery, SRS/SBRT, proton therapy, brachytherapy, and other radiation services.
Treatment Delivery: Proposed payment increases for key radiation treatment delivery codes include:
- CPT 77402: +26%
- CPT 77407: +17%
- CPT 77412: +14%
SRS and SBRT: Proposed payment rates for stereotactic radiosurgery (SRS) and stereotactic body radiation therapy (SBRT) services are also increasing, with several codes seeing approximately 14% increases.
Proton Therapy: Proposed OPPS payment rates for proton therapy services are increasing, with CPT codes 77520, 77522, 77523, and 77525 receiving proposed increases ranging from approximately 12% to 14%.
Site-Neutral Payment Expansion: CMS proposes expanding site-neutral payment policies to include certain imaging services furnished in excepted off-campus provider-based departments, while maintaining an exemption for rural sole community hospitals.
Biology-Guided Radiation Therapy (BgRT): CMS is proposing revised APC assignments and payment rates for BgRT services as additional claims data becomes available.
340B Drug Payment Changes: CMS proposes changing reimbursement for 340B-acquired drugs to Average Sales Price (ASP) minus 33.4%, replacing the current ASP +6% methodology. This change could have implications for outpatient oncology services and radiopharmaceuticals.
Next Steps
The 2027 Proposed Rules include several significant changes that could affect radiation oncology reimbursement, with the impact varying considerably by practice setting and service mix. We encourage radiation oncology providers to review these proposals carefully and evaluate how the changes could affect their organization’s financial and operational outlook.
The MPFS proposed rule also highlights the importance of advocacy from the radiation oncology community. Providers and stakeholders are encouraged to submit data-driven comments regarding the potential impact of proposed payment changes on patient access, staffing, technology investment, treatment availability, and the financial stability of cancer care programs. Comments are due by September 14, 2026.
Fill out the form on this page to download the full RBS 2027 Proposed Rule Summary, including detailed analysis, year-to-year reimbursement comparisons, code-specific payment information, and examples illustrating the potential impact across different practice settings.
Have questions about how these proposed changes could affect your organization? We’re here to help. Contact Radiation Business Solutions for more information or assistance navigating the 2027 proposed updates.


