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ASTRO submits comments to CMS on Efficiency Adjustment and IGRT billing confusion

February 11, 2026

On February 5, ASTRO sent comments to the Centers for Medicare & Medicaid Services (CMS) raising serious concerns about two policy areas affecting radiation oncology: the new Efficiency Adjustment (EA) and increasing billing confusion related to CPT 77387.

Efficiency Adjustment

ASTRO continues to recommend that CMS suspend implementation of the EA until specialty specific data justifies such an adjustment and limit any future adjustments to codes not recently reviewed. As an example, it was noted that following the AMA RUC’s January 2025 review of radiation oncology codes, physician work RVUs for IGRT were reduced based on updated survey data from practitioners in the field. The efficiency adjustment reduced the work RVUs for this code by an additional 2.85%, despite the recency of the code’s review and no time to achieve further efficiency.

77387 Professional Component Billing Confusion

Since January 1, there has been inconsistency with the way 77387, Guidance for localization of target volume for delivery of radiation treatment, includes intrafraction tracking, when performed, is being processed and reimbursed amongst payers. ASTRO has heard from its members that Noridian is denying 77387-26 with denial code C04, citing an inappropriate modifier, while other MACs are accepting the code. ASTRO is concerned that other MACs could start to deny the code for the same rationale, if they have not already. There is confusion due to the variable ways in which this code is being billed, and it is leading to unnecessary denials and reprocessed claims through the first months of 2026. ASTRO reiterated its previous recommendation to only display the professional component for 77387, removing the global code.

Read ASTRO’s letter to CMS for additional information.

 

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