The landscape of radiation oncology coding and reimbursement is undergoing the most significant shift in over a decade. With ongoing Medicare payment cuts and increased practice expenses, the financial stability of radiation oncology practices is at stake.
Next year, the introduction of new radiation treatment delivery and image guidance coding and the revaluation of practice expense across all medical specialties could dramatically impact reimbursement rates. Understanding these changes is essential to practice business planning, as well as the need to engage in advocacy to ensure that patients have access to high-quality care.
Quick History Behind the Code Revisions
Radiation oncology has faced a series of financial challenges in recent years. Payment reductions of 25% under the Medicare Physician Fee Schedule (MPFS) since 2013 and shifts toward hypofractionation have strained practice operating margins, particularly in community-based and freestanding clinics. In addition, equipment, staffing and operations costs continue to increase, making it harder for practices to maintain high-quality care and remain financially viable.
Since 2009, CMS has scrutinized the construct and payment for radiation treatment delivery and image guidance codes, which represent about half of the total reimbursement value for radiation oncology services. ASTRO and ACRO have worked with the AMA and CMS to ensure fair valuation of these codes over the years.
However, past attempts at reform, including the ill-fated Radiation Oncology Alternative Payment Model (RO Model), have left the specialty in limbo. Additionally, the practice expense (PE) component of the current MPFS payment methodology, representing about three-fourths of reimbursement for radiation oncology, has not been updated since 2010. Both policy efforts will have significant implications for radiation oncology.
Why These Changes Matter
In 2024, the AMA CPT Editorial Panel approved significant changes to radiation oncology treatment delivery and image guidance codes (see table below). These changes reflect advances in technology and care delivery, which can dramatically impact how these services will be valued under the MPFS. ASTRO and ACRO have been actively engaged in the CPT and RUC (Relative Value Scale Update Committee) processes, advocating for radiation oncology’s unique needs to be accounted for in these discussions.
| CPT Code | Description | Changes |
| 77402 | Radiation treatment delivery, >=1 MeV; simple | Revised to consolidate and more clearly specify services provided for radiation treatment delivery |
| 77407 | Radiation treatment delivery, >=1 MeV; intermediate | |
| 77412 | Radiation treatment delivery, >=1 MeV; complex | |
| 77014 | Computed tomography guidance for placement of radiation therapy fields | Delete |
| 77385 | Intensity modulated radiation treatment delivery (IMRT), includes guidance and tracking, when performed; simple | Delete |
| 77386 | Intensity modulated radiation treatment delivery (IMRT), includes guidance and tracking, when performed; complex | Delete |
Additionally, CMS is pursuing an update to the PE component of the MPFS that will impact services across the House of Medicine. The AMA is seeking to influence the update via the Physician Practice Information Survey (PPIS). Based on the survey, which included limited responses from radiation oncology, the AMA recommended bundling radiation oncology practice expense with that of diagnostic radiology, nuclear medicine and interventional radiology, creating a radiology PE/hour rate that is 40% below the existing rate set for radiation oncology. This dramatic reduction, if implemented, could artificially undervalue the significant capital expense of radiation therapy treatment.
To address this, an analysis of radiation oncology practice expense is underway to inform CMS decision making associated with updating the reimbursement formula.
What This Means for Providers and Patients
The treatment delivery code and image guidance changes, as well as the practice expense update, will impact how radiation therapy is paid for, and it is crucial that providers understand what may be coming:
- Financial implications: Shifts in reimbursement rates, which could affect the financial stability of practices, particularly those in underserved areas.
- Operational adjustments: Modifications to billing processes, requiring training for administrative and clinical staff.
- Access to care: If reimbursement rates do not adequately reflect the cost of treatment, some practices may struggle to offer certain services, potentially limiting patient access to the latest advances in radiation therapy.
What's Next?
With these major changes on the horizon, the need for payment stability has never been greater. The Radiation Oncology Case Rate Act (ROCR) legislation, supported by ASTRO and ACRO, is designed to provide a sustainable reimbursement structure that ensures practices can continue delivering high-quality care. By addressing the financial uncertainties tied to evolving coding and valuation systems, ROCR offers a viable path forward for providers navigating these complex changes.
In addition to ROCR, ASTRO and ACRO will continue advocating with CMS for fair valuations that reflect the true costs and expertise involved in radiation therapy. The MPFS proposed rule is expected in July 2025, with implementation on January 1, 2026, and we expect more details surrounding changes to the treatment delivery and image guidance codes and the PE update to appear in the regulations.
In the meantime, ASTRO and ACRO encourage radiation oncology professionals to stay engaged, prepare for changes and advocate for payment reform.
Dr. Yashar is ASTRO’s CPT Advisor, Dr. Rewari is ASTRO’s RUC Advisor, Dr. Jahraus is ACRO’s RUC Advisor and Dr. Thomas is ACRO’s CPT Advisor.
