Medicare PFS 2026 proposed rule

[NotMattSpraker]

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I will definitely be writing a letter and I think we need to encourage EVERYBODY to do the same. I’m preparing it and will have it available for people.

Comment here as well:

Regulations.gov

www.regulations.gov

 

[Gfunk6]

I've heard that it is a far superior strategy to speak with a unified voice to CMS, hence why ASTRO/ACRO were in lock-step. If a bunch of people send letters saying contrary things, then CMS tends to get fed up and do what they want anyway.

Obviously, the advice above reeks of entrenched institutional rot but I've heard this from people I trust who are in the same boat as me (non-academic, non-large hospital owned private practice). When the reimbursement doesn't change exactly but coding does, people change their coding and treatment practices to prevent loss of monies or try to game the system for even more. A tale as old as time in medicine.

 

[BobbyHeenan]

I've listened to this ASTRO thing and once again they give this line "if you were doing KV image guidance, then this new IGRT code is a bump UP for you."

Is this intentionally obtuse or is this dude just ignorant of IGRT billing in 2025 (doubtful)?

NO ONE WAS DOING KV IMAGING. There is no talk of weighting the bundling calculation by code usage. It's sugar coating the a crap sandwich reality.

So frustrating.

 

[NotMattSpraker]

I've heard that it is a far superior strategy to speak with a unified voice to CMS, hence why ASTRO/ACRO were in lock-step. If a bunch of people send letters saying contrary things, then CMS tends to get fed up and do what they want anyway.

If that is the case, why did ASTRO/ACRO split off from the ACR in the first place? 🙂

This is a rhetorical question.

 

[grenz]

If that is the case, why did ASTRO/ACRO split off from the ACR in the first place? 🙂

This is a rhetorical question.

Those were the simple days before Medicare— when the old and uninsured just died

 

[NotMattSpraker]

In the 50s it was literally just a club with no formal organizational structure. At that time as far as I can tell they did not have any significant government relations. That all continued through the ACR. ASTRO did not become a fully independent society from ACR until the late 80s.

Interestingly, it started out as a club of people who felt there needed to be more focused efforts for therapeutic radiation separate from radiology. I dont necessarily agree that was a good decision. Its really hard to feel that way as someone who only really has been exposed to radiation oncology since the early 2010s.

Im not commenting on separate training and board certification, this is purely with respect to lobbying and "professional support" so to speak.

ACRO formed not even 10 years after ASTRO, primarily because some felt ASTRO was "too academic" and did not represent community practitioners, sort of funny when you look at it today with their board of chancellors being majority academic.

In the more "complex" times of 2025, I genuinely think we could be better off lobbying as a division of radiology. Just my opinion. Id maybe feel differently if we had different or at least a more varied set of individuals leading the charge.

One of ASTROs government relations leaders was let go, the other was not. Maybe things will improve with the change.

 

[Ray D. Ayshun]

Coming back to an earlier discussion re IGRT in DIBH cases, I'm wondering about getting paid as an RVU based doc. I still setup to kvs, but we're billing G6017 and not G6002, the former having no prof rvus and the latter 0.39. I'm not using surface guidance. Should I be billing G6002? And what kind of imaging/codes are people doing for VMAT APBI?

 

[TheWallnerus]

If no surface guidance no G6017. If you do kV matching that code is G6002. Most people use CBCT for APBI; VMAT (or not) would be unrelated to the IGRT chosen. If you’re hospital based you always have the opportunity to perhaps use 77387-26 when you are worried about not getting RVUs.

 

[deleted1217978]

Coming back to an earlier discussion re IGRT in DIBH cases, I'm wondering about getting paid as an RVU based doc. I still setup to kvs, but we're billing G6017 and not G6002, the former having no prof rvus and the latter 0.39. I'm not using surface guidance. Should I be billing G6002? And what kind of imaging/codes are people doing for VMAT APBI?

Yes, you should be billing G6002 when you do kV images when allowed to for IGRT for 3D breast. For VMAT you should be billing 77014. You've left a lot of RVUs on the table. Won't matter in a few months, I guess.

 

[medgator]

Yes, you should be billing G6002 when you do kV images when allowed to for IGRT for 3D breast. For VMAT you should be billing 77014. You've left a lot of RVUs on the table. Won't matter in a few months, I guess.

Is it set in stone yet?

 

[Ray D. Ayshun]

Yes, you should be billing G6002 when you do kV images when allowed to for IGRT for 3D breast. For VMAT you should be billing 77014. You've left a lot of RVUs on the table. Won't matter in a few months, I guess.

It's says g6017 and the other two can't be billed simultaneously. You're saying bill 6017 tech and one of the others prof?

 

[Ray D. Ayshun]

If no surface guidance no G6017. If you do kV matching that code is G6002. Most people use CBCT for APBI; VMAT (or not) would be unrelated to the IGRT chosen. If you’re hospital based you always have the opportunity to perhaps use 77387-26 when you are worried about not getting RVUs.

We only use it in the DIBH context. Set up to kv/kv then do DIBH with RPM. And I'm doing that imaging. Have just been billing g6017 only when dibh employed.

 

[deleted1217978]

It's says g6017 and the other two can't be billed simultaneously. You're saying bill 6017 tech and one of the others prof?

Assuming you are using surface guidance for DIBH, you should bill 77387 and G6002.

 

[TheWallnerus]

It's says g6017 and the other two can't be billed simultaneously. You're saying bill 6017 tech and one of the others prof?

You can’t bill any IGRT tech with IMRT.

What is your hypothetical exactly and I can give a better answer.

 

[Ray D. Ayshun]

You can’t bill any IGRT tech with IMRT.

What is your hypothetical exactly and I can give a better answer.

No hypothetical really. The way I read things, G6017 should be billed when employing motion management of any type. Though I don't employe true SGRT, the system we use is a surrogate and fits the description. In turn, the billing guidelines seem to suggest that 6002 or 77014 can't be billed concurrently,

 

[TheWallnerus]

No hypothetical really. The way I read things, G6017 should be billed when employing motion management of any type. Though I don't employe true SGRT, the system we use is a surrogate and fits the description. In turn, the billing guidelines seem to suggest that 6002 or 77014 can't be billed concurrently,

I wouldn’t agree. You mentioned DIBH. You bill 77293 for that. If you were gating based on kV fiducials, you’d bill 6002 not 6017. For all practical purposes 6017 is just for VisionRT (or “surface guidance”). You could bill 6017 I guess to treat the tip of the nose in facemask setup. I would not call 6017 “motion management” in that instance. Again I think the code closest to “motion management” is 77293.

 

[deleted1217978]

77293 is a code billed at simulation for a 4DCT. DIBH sim does not capture all respiratory motion so should not be billed for DIBH. It would be nice to get some wRVUs for DIBH vs. non DIBH treatments, but there is no extra physician work that is paid for DIBH vs. non DIBH, it's all on the tech side. Which is true as I cannot think of any additional work we do for DIBH vs. non DIBH. It's just which scan we draw on and whether we approve light fields on breath held vs. breathing skin. No additional work.

So, for daily treatments in the hospital you should bill 77387 for both DIBH and tech side of kV imaging and G6002, which get you the IGRT wRVUs.

From CMS:

• CPT® code 77387, guidance for localization of target volume for delivery of radiation treatment delivery, includes intrafraction tracking when performed. This CPT® code, however, was not assigned a reimbursement value in the Medicare Physician Fee Schedule. Instead, providers are instructed to report IGRT services using the following HCPCS G-codes and CPT® code as appropriate:

G6001
G6002
G6017
77014

These codes can also be used to report the professional component of IGRT services for providers in a hospital setting by attaching the -26 modifier to the codes.

Hospitals do use CPT® code 77387 per the Hospital Outpatient Prospective Payment System (HOPPS). This technical component is reported with the -TC modifier. However, the technical component of IGRT code 77387 is bundled into IMRT delivery codes 77385 and 77386.

77387-TC should always be reported when image guidance is performed with conventional (non-IMRT, non-SRS/SBRT) CPT® codes 77402, 77407, and 77412. However, 77387-TC is not reimbursed separately in the hospital setting because it is packaged into the Ambulatory Payment Classification with the treatment delivery service with which it is performed. Reporting the service is still important as the data is collected by CMS and might be utilized in future HOPPS rate-setting.

Most freestanding centers will report claims under the Medicare Physician Fee Schedule, and therefore, will report G-codes for treatment delivery and IGRT to the Medicare payer.

 

[TheWallnerus]

77293 is a code billed at simulation for a 4DCT. DIBH sim does not capture all respiratory motion so should not be billed for DIBH

But what if you did capture all respiratory motion at sim, in other words did a 4DCT, to compare excursion versus DIBH. (I should have been more clear.)

 

[deleted1217978]

But what if you did capture all respiratory motion at sim, in other words did a 4DCT, to compare excursion versus DIBH. (I should have been more clear.)

I feel like evicore would kick you in the nuts for this, but just a hunch.

Radiation Therapy Billing FAQ: Part One | Radformation

Billing is an essential function in radiation therapy departments but can be challenging for any clinician. Part 1.

blog.radformation.com

3. Should a 4DCT be billed with a deep inspiration breath hold (DIBH) breast plan?
Respiratory motion management simulation (+77293) is performed when requested by a radiation oncologist to account for breathing-related motion of lung or abdominal tumors being targeted with radiation. Commonly referred to as a 4DCT, this procedure involves acquiring additional CT images during the full breathing range of the patient while using external fiducials or respiratory bellows to track breathing motion. Using the CT images acquired over the entire respiratory cycle, the radiation oncologist contours the moving tumor volume to account for the breathing-related motion of the tumor, resulting in a composite ITV. Even though the 4DCT images are acquired at the time of simulation, this add-on code is billed on the same date of service with either a 3D conformal radiotherapy plan (77295) or IMRT planning (77301), even though the work involved may take place over many days. While a DIBH breast simulation typically involves acquiring a free-breathing and a breath-hold CT scan, these scans do not include the full respiration motion. Therefore, a respiratory motion management simulation (+77293) charge would not be reportable with DIBH breast plans.

 

[BobbyHeenan]

If no surface guidance no G6017. If you do kV matching that code is G6002. Most people use CBCT for APBI; VMAT (or not) would be unrelated to the IGRT chosen. If you’re hospital based you always have the opportunity to perhaps use 77387-26 when you are worried about not getting RVUs.

Agree with this.

for APBI I use a CBCT and bill the 77014-26 (pro code in hospital based facility).

For DIBH L sided 3D cases I bill the G6017 as we use Align/Vision RT surface guidance system. This has no wRVU assigned to it but it pays really well - In the last quarter I have been paid for both medicare and some private payers for htis.

 

[Ray D. Ayshun]

Agree with this.

for APBI I use a CBCT and bill the 77014-26 (pro code in hospital based facility).

For DIBH L sided 3D cases I bill the G6017 as we use Align/Vision RT surface guidance system. This has no wRVU assigned to it but it pays really well - In the last quarter I have been paid for both medicare and some private payers for htis.

This is the rub kinda, right? You must be collections based. It seems like, as usual, you can make an argument for either code in certain contexts, but which is better depends on how you're compensated.

 

[BobbyHeenan]

This is the rub kinda, right? You must be collections based. It seems like, as usual, you can make an argument for either code in certain contexts, but which is better depends on how you're compensated.

You got it.

If on a wRVU contract better for you (but not hospital) to bill G6002 if you are taking daily kV's in addition to the surface alignment.

 

[deleted1217978]

For DIBH L sided 3D cases I bill the G6017 as we use Align/Vision RT surface guidance system. This has no wRVU assigned to it but it pays really well - In the last quarter I have been paid for both medicare and some private payers for htis.

Interesting. So medicare is paying G6017 on the pro side higher than what they pay for G6002. I have never heard of a pro code that medicare pays for that does not have a wRVU component. The hospital is billing the more profitable code (G6017 only instead of properly billing 77387 + G6002), both on an absolute basis and a relative basis in terms of their margin having to pay out wRVUs. If I were Ray, I would bring this to their attention and request retroactive reimbursement of 0.39 wRVU for every G6017 charge since working there. Good luck.

 

[Ray D. Ayshun]

Interesting. So medicare is paying G6017 on the pro side higher than what they pay for G6002. I have never heard of a pro code that medicare pays for that does not have a wRVU component. The hospital is billing the more profitable code (G6017 only instead of properly billing 77387 + G6002), both on an absolute basis and a relative basis in terms of their margin having to pay out wRVUs. If I were Ray, I would bring this to their attention and request retroactive reimbursement of 0.39 wRVU for every G6017 charge since working there. Good luck.

I just brought it to my attention and you all confirmed. Thanks. Will do things differently going forward.

 

[BobbyHeenan]

Interesting. So medicare is paying G6017 on the pro side higher than what they pay for G6002. I have never heard of a pro code that medicare pays for that does not have a wRVU component. The hospital is billing the more profitable code (G6017 only instead of properly billing 77387 + G6002), both on an absolute basis and a relative basis in terms of their margin having to pay out wRVUs. If I were Ray, I would bring this to their attention and request retroactive reimbursement of 0.39 wRVU for every G6017 charge since working there. Good luck.

Yes.

Our medicare LCD recently assigned it a value (or started paying for it) but I believe still no wRVU for it. It does pay better than G6002 and maybe even better than a CBCT (I'd have to check on that).

this is all for naught though, presuming new CMS codes go through it's all going to be one code no matter what (on the professional side) soon enough.

 

[deleted1217978]

Yes.

Our medicare LCD recently assigned it a value (or started paying for it) but I believe still no wRVU for it. It does pay better than G6002 and maybe even better than a CBCT (I'd have to check on that).

this is all for naught though, presuming new CMS codes go through it's all going to be one code no matter what (on the professional side) soon enough.

I am confused though how the money actually flows in the hospital. Most charges are bundled in an APC so they get a flat rate for a treatment regardless of what is charged. I don't know if G6017 is separate from this. If so, that would be a little nefarious.

 

[BobbyHeenan]

I am confused though how the money actually flows in the hospital. Most charges are bundled in an APC so they get a flat rate for a treatment regardless of what is charged. I don't know if G6017 is separate from this. If so, that would be a little nefarious.

I have no clue how our hospital is billing on the technical side. We just bill pro fees. All my comments above pertain only to the pro side.

 

[Ray D. Ayshun]

I am confused though how the money actually flows in the hospital. Most charges are bundled in an APC so they get a flat rate for a treatment regardless of what is charged. I don't know if G6017 is separate from this. If so, that would be a little nefarious.

At my place, G6017 is labelled as a Professional code. In turn, the hospital is billing it and collecting it, which they do globally, and paying the physician for the wRVU value of a given code, which in this case is $0.

 

[NotMattSpraker]

I am confused though how the money actually flows in the hospital.

We all are 🙂

 

[BobbyHeenan]

At my place, G6017 is labelled as a Professional code. In turn, the hospital is billing it and collecting it, which they do globally, and paying the physician for the wRVU value of a given code, which in this case is $0.

Wow. I'd be having a talk with them about that.

It is a professional code.

It may not be fully nefarious, as this is all very confusing (and an oddity that it is paying but has no wRVU)....but you're right, it's a professional code. You should be getting compensated for it.

 

[deleted1217978]

Wow. I'd be having a talk with them about that.

It is a professional code.

It may not be fully nefarious, as this is all very confusing (and an oddity that it is paying but has no wRVU)....but you're right, it's a professional code. You should be getting compensated for it.

The problem with hospital employment is when you start making reasonable demands like this (e.g., honor my contract and pay me for what I do), somebody in HR will chime in "you know, we can just pay a locums a $2200/day flat rate instead of paying Ray for each wRVU and keep rotating them out indefinitely." The major difference between a good hospital job and a bad hospital job is whether senior admin agrees that this is a good idea.

 

[Ray D. Ayshun]

Wow. I'd be having a talk with them about that.

It is a professional code.

It may not be fully nefarious, as this is all very confusing (and an oddity that it is paying but has no wRVU)....but you're right, it's a professional code. You should be getting compensated for it.

Eh, I'm doing fine. This is just one more example of the insanity that is rad onc coding. It'll be fixed going forward. Not worth talking about with them as to some degree their ignorance is my bliss. Any time they become aware of anything, good or bad, it only gets worse.

 

[BobbyHeenan]

Eh, I'm doing fine. This is just one more example of the insanity that is rad onc coding. It'll be fixed going forward. Not worth talking about with them as to some degree their ignorance is my bliss. Any time they become aware of anything, good or bad, it only gets worse.

I think this is the right play on your part. If for whatever reason the new code/bundling changes don't go through I'd push harder. You're wise to keep the bean counters away in many scenarios.

 

[Sheldor]

Anybody know what the current status of this is? When does it become official official and we see if they changed anything?

 

[HolySmokes]

Final rule is usually released in the first 1-2 weeks of November. Unsure how that timeline may be affected by the shutdown, though

 

[GapCalc]

Final rule is out:

https://public-inspection.federalregister.gov/2025-19787.pdf

 

[medgator]

Final rule is out:

https://public-inspection.federalregister.gov/2025-19787.pdf

Can someone tell me where in the 2375 pages the relevant info is?

 

[Pointless]

Best I can tell, the removal of 77014 and replacement with 77387 went through. 0.85 wRVU ---> 0.70 wRVU for IGRT. So, a 20% haircut on IGRT.

Cool.

 

[A_DeMichele]

From the Final Rule text:

• CPT 77014 (CT guidance for radiation therapy delivery) is deleted / no longer reported for IGRT.
  
  The document notes removal of CT-guidance codes from radiation treatment delivery workflows:
• CPT 77387 is now the designated treatment guidance code for IGRT (regardless of modality such as kV-CBCT, MV-CT, or 2D/3D imaging).

 

[TheWallnerus]

Best I can tell, the removal of 77014 and replacement with 77387 went through. 0.85 wRVU ---> 0.70 wRVU for IGRT. So, a 20% haircut on IGRT.

Cool.

About a 80% haircut if you’re a plebe freestander

 

[RadOncMegatron]

ASTRO Official Statement:

Medicare Finalizes Significant Radiation Therapy Payment Changes for 2026​

Today, the Centers for Medicare and Medicaid Services (CMS) issued the final Medicare Physician Fee Schedule rule for 2026, with significant swings in payment among radiation services, among practice settings and among technical and professional payments. ASTRO is disappointed by additional cuts to radiation oncology, as CMS estimates a -1% overall impact for radiation oncology.

The agency expects that 41% of radiation oncologists will see a decline of -2% to -5% in total RVUs in 2026. CMS estimates a broad distribution of payment impacts among radiation oncologists due to the variety of policy changes.

Across the fee schedule, CMS made almost no changes to the policies they proposed in July. ASTRO is pleased that CMS finalized its proposal to use relative values for traditionally more stable hospital outpatient data to inform freestanding technical payments for the revised treatment delivery codes 77402, 77407 and 77412.

However, ASTRO strongly disagrees with CMS’ decision to maintain the proposed hospital payment group assignments for the revised codes, resulting in RVUs for 77402 at 2.71; 77407 at 6.47; and 77412 at 14.45. ASTRO remains deeply disappointed by the finalized valuation for 77407. Since the proposed rule was released in July, we have consistently engaged with CMS to raise concerns that the proposal for this essential service was not accurately valued and to strongly urge reconsideration in the final rule. Unfortunately, those recommendations were not adopted. We will continue to communicate our concerns to the agency, as we believe this outcome is unfair to our members and the patients they serve.

While this represents a potentially reasonable RVU for the most complex code (77412) and treatments, the RVUs for the intermediate code (77407) and simple code (77402) are inappropriately low. Of note, freestanding centers will benefit from CMS finalizing a change to the indirect practice expense methodology that shifts resources to freestanding centers. In addition, since hospital chargemaster data will be used to inform reimbursement for the revised treatment delivery codes, both hospital and freestanding reimbursement will adjust over time to reflect these costs. CMS has not yet issued the hospital outpatient payment final rule.

ASTRO is also disappointed that CMS finalized a new efficiency adjustment that will reduce physician work relative value units by 2.5% for many professional codes, which will negatively impact radiation oncologists and specialists. ASTRO is collaborating with a broad coalition of stakeholders to express our unified concern that the efficiency adjustment is both arbitrary and divisive within the physician community. Unfortunately, despite the strong and consistent opposition from ASTRO and affected specialties, CMS did not act on these concerns.

ASTRO will continue working with the radiation oncology and physician community to advocate on these and other outstanding physician payment issues. This rule underscores concerns about the volatility of the fee schedule, which is among the reasons ASTRO continues to pursue the Radiation Oncology Case Rate Act (H.R. 2120/S. 1031), which would freeze radiation therapy payments upon passage and stabilize payments over the long term. More than 135 organizations across the radiation oncology community support the ROCR Act.

ASTRO will provide a detailed summary and more analysis in coming days.

 

[TheWallnerus]

ASTRO Official Statement:

Medicare Finalizes Significant Radiation Therapy Payment Changes for 2026​

Today, the Centers for Medicare and Medicaid Services (CMS) issued the final Medicare Physician Fee Schedule rule for 2026, with significant swings in payment among radiation services, among practice settings and among technical and professional payments. ASTRO is disappointed by additional cuts to radiation oncology, as CMS estimates a -1% overall impact for radiation oncology.

The agency expects that 41% of radiation oncologists will see a decline of -2% to -5% in total RVUs in 2026. CMS estimates a broad distribution of payment impacts among radiation oncologists due to the variety of policy changes.

Across the fee schedule, CMS made almost no changes to the policies they proposed in July. ASTRO is pleased that CMS finalized its proposal to use relative values for traditionally more stable hospital outpatient data to inform freestanding technical payments for the revised treatment delivery codes 77402, 77407 and 77412.

However, ASTRO strongly disagrees with CMS’ decision to maintain the proposed hospital payment group assignments for the revised codes, resulting in RVUs for 77402 at 2.71; 77407 at 6.47; and 77412 at 14.45. ASTRO remains deeply disappointed by the finalized valuation for 77407. Since the proposed rule was released in July, we have consistently engaged with CMS to raise concerns that the proposal for this essential service was not accurately valued and to strongly urge reconsideration in the final rule. Unfortunately, those recommendations were not adopted. We will continue to communicate our concerns to the agency, as we believe this outcome is unfair to our members and the patients they serve.

While this represents a potentially reasonable RVU for the most complex code (77412) and treatments, the RVUs for the intermediate code (77407) and simple code (77402) are inappropriately low. Of note, freestanding centers will benefit from CMS finalizing a change to the indirect practice expense methodology that shifts resources to freestanding centers. In addition, since hospital chargemaster data will be used to inform reimbursement for the revised treatment delivery codes, both hospital and freestanding reimbursement will adjust over time to reflect these costs. CMS has not yet issued the hospital outpatient payment final rule.

ASTRO is also disappointed that CMS finalized a new efficiency adjustment that will reduce physician work relative value units by 2.5% for many professional codes, which will negatively impact radiation oncologists and specialists. ASTRO is collaborating with a broad coalition of stakeholders to express our unified concern that the efficiency adjustment is both arbitrary and divisive within the physician community. Unfortunately, despite the strong and consistent opposition from ASTRO and affected specialties, CMS did not act on these concerns.

ASTRO will continue working with the radiation oncology and physician community to advocate on these and other outstanding physician payment issues. This rule underscores concerns about the volatility of the fee schedule, which is among the reasons ASTRO continues to pursue the Radiation Oncology Case Rate Act (H.R. 2120/S. 1031), which would freeze radiation therapy payments upon passage and stabilize payments over the long term. More than 135 organizations across the radiation oncology community support the ROCR Act.

ASTRO will provide a detailed summary and more analysis in coming days.

Remember in Spinal Tap when they look at their album cover, and it’s just totally black. No text or anything. And someone says how much more black could it be and they go “None. None more black.”

ASTRO could be none more ineffective with CMS.

The RVU story doesn’t tell the full story of the total rad onc haircut.

 

[winstonfoot5]

ASTRO Official Statement:

Medicare Finalizes Significant Radiation Therapy Payment Changes for 2026​

Today, the Centers for Medicare and Medicaid Services (CMS) issued the final Medicare Physician Fee Schedule rule for 2026, with significant swings in payment among radiation services, among practice settings and among technical and professional payments. ASTRO is disappointed by additional cuts to radiation oncology, as CMS estimates a -1% overall impact for radiation oncology.

The agency expects that 41% of radiation oncologists will see a decline of -2% to -5% in total RVUs in 2026. CMS estimates a broad distribution of payment impacts among radiation oncologists due to the variety of policy changes.

Across the fee schedule, CMS made almost no changes to the policies they proposed in July. ASTRO is pleased that CMS finalized its proposal to use relative values for traditionally more stable hospital outpatient data to inform freestanding technical payments for the revised treatment delivery codes 77402, 77407 and 77412.

However, ASTRO strongly disagrees with CMS’ decision to maintain the proposed hospital payment group assignments for the revised codes, resulting in RVUs for 77402 at 2.71; 77407 at 6.47; and 77412 at 14.45. ASTRO remains deeply disappointed by the finalized valuation for 77407. Since the proposed rule was released in July, we have consistently engaged with CMS to raise concerns that the proposal for this essential service was not accurately valued and to strongly urge reconsideration in the final rule. Unfortunately, those recommendations were not adopted. We will continue to communicate our concerns to the agency, as we believe this outcome is unfair to our members and the patients they serve.

While this represents a potentially reasonable RVU for the most complex code (77412) and treatments, the RVUs for the intermediate code (77407) and simple code (77402) are inappropriately low. Of note, freestanding centers will benefit from CMS finalizing a change to the indirect practice expense methodology that shifts resources to freestanding centers. In addition, since hospital chargemaster data will be used to inform reimbursement for the revised treatment delivery codes, both hospital and freestanding reimbursement will adjust over time to reflect these costs. CMS has not yet issued the hospital outpatient payment final rule.

ASTRO is also disappointed that CMS finalized a new efficiency adjustment that will reduce physician work relative value units by 2.5% for many professional codes, which will negatively impact radiation oncologists and specialists. ASTRO is collaborating with a broad coalition of stakeholders to express our unified concern that the efficiency adjustment is both arbitrary and divisive within the physician community. Unfortunately, despite the strong and consistent opposition from ASTRO and affected specialties, CMS did not act on these concerns.

ASTRO will continue working with the radiation oncology and physician community to advocate on these and other outstanding physician payment issues. This rule underscores concerns about the volatility of the fee schedule, which is among the reasons ASTRO continues to pursue the Radiation Oncology Case Rate Act (H.R. 2120/S. 1031), which would freeze radiation therapy payments upon passage and stabilize payments over the long term. More than 135 organizations across the radiation oncology community support the ROCR Act.

ASTRO will provide a detailed summary and more analysis in coming days.

can someone translate this - how bad is this

 

[grenz]

can someone translate this - how bad is this

I think this comment kind of encapsulates why we need an advocacy organization. They aren’t going to win every battle, but they did win some positives in the negotiations preceding the proposed rule in July (notably benefitting freestanding centers). The nitty gritty details of Medicare policy are just too Byzantine for any one rad onc to understand and advocate for in a grassroots way.

There are posters who have acknowledged being disappointed with both ASTRO and ACRO, and belonging to neither. It would be a mistake if we do that en masse.

 

[TheWallnerus]

I think this comment kind of encapsulates why we need an advocacy organization. They aren’t going to win every battle, but they did win some positives in the negotiations preceding the proposed rule in July (notably benefitting freestanding centers

Maybe I’m dense, but ASTRO saying freestanding centers have a benefit here makes no sense to me. In 2025, a freestanding center will get $350 for an IMRT fraction and $140 for the accompanying IGRT. In 2026 they’ll get $300 for the IMRT and $30 for the IGRT.

How on any planet have they benefitted.

ASTRO’s “bragging” about some freestanding benefit doled from their hand is either tone deaf let-them-eat-cake ineptitude or expert-level gaslighting as everything goes according to plan.

This is advocacy we DON’T need.

 

[medgator]

Maybe I’m dense, but ASTRO saying freestanding centers have a benefit here makes no sense to me. In 2025, a freestanding center will get $350 for an IMRT fraction and $140 for the accompanying IGRT. In 2026 they’ll get $300 for the IMRT and $30 for the IGRT.

How on any planet have they benefitted.

More of the same.... decades now, really

 

[BobbyHeenan]

Maybe I’m dense, but ASTRO saying freestanding centers have a benefit here makes no sense to me. In 2025, a freestanding center will get $350 for an IMRT fraction and $140 for the accompanying IGRT. In 2026 they’ll get $300 for the IMRT and $30 for the IGRT.

How on any planet have they benefitted.

ASTRO’s “bragging” about some freestanding benefit doled from their hand is either tone deaf let-them-eat-cake ineptitude or expert-level gaslighting as everything goes according to plan.

This is advocacy we DON’T need.

It’s actually similar to what they were saying about igrt …”but you’ll get a bump from for kV orthogonal imaging.”

While 90% + of IGRT is CBCT, it doesn’t matter if you bump up the kV reimbursement.

====

I don’t know much about freestanding billing but I did hear people taking about that indirect practice expense calculation so maybe that actually did help them in final rule?

 

[Ray D. Ayshun]

We still have a range of dose/fraction options and boost options (seq/sib) for treatment of a given body site/context. Choose wisely. This is standard course from money folks, kind of like disallowing consult/sim/planning charges on same day, even if it would be easier and quicker for the patient. They force us to choose between remunerative and ethical, knowing we'll generally choose the latter. I think it's fair to live down to their standards more often.

 

[RickyScott]

How much is cms imrt reimbursement per fraction down in the last 15 years on the technical side? Yet large academic departments are more profitable than ever per patient!

Sure, Astro is inept w/cms
but they are downright malignant when it comes to the supply of radiation oncologists. The job market and salaries are driven mostly by supply. There is a shortage of doctors in virtually every specialty except the one that led in residency expansion.

 

[RickyScott]

How much is cms imrt reimbursement per fraction down in the last 15 years on the technical side? Yet large academic departments are more profitably than ever per patient!

Sure, Astro is inept w/cms
but they are downright malignant when it comes to the supply of radiation oncologists. The job market and salaries are driven mostly by supply. There is a shortage of doctors in virtually every specialty except the one that led in residency expansion.

There seems to be a lot more attention focused on these cuts than programs like univ of Miami expanding resident numbers . (entering class of 5.)There are a lot of bad apples in radonc- or we wouldn’t be in this position.