MPFS 2027 Proposed Rule: Strong Gains for Treatment Delivery Codes Tempered by Other Cuts
July 14, 2026
CMS has released the calendar year (CY) 2027 Medicare Physician Fee Schedule (MPFS) proposed rule estimating a positive impact of 3% for radiation oncology overall and 5% for freestanding centers.
Initial analysis of the proposal indicates that ASTRO's advocacy is primed to secure strong improvements to the key radiation treatment delivery codes. However, other important radiation oncology services —including planning, management and SBRT—would see cuts generally ranging from 3-6%. Individual practice impact will vary depending on service mix.
These reductions and continued need for treatment delivery code boosts illustrate the urgency for comprehensive payment reform. The Radiation Oncology Case Rate (ROCR) Act offers a solution, and momentum is building with bipartisan support in Congress with more than 40 supporters. On July 14, ASTRO hosted a Congressional briefing for nearly 50 congressional staff in conjunction with the House Cancer Caucus, while ASTRO physician leaders met with key lawmakers in the House and Senate to push this legislation forward.
Conversion Factor
There are two separate conversion factors (CF):
- $33.1693 for qualifying alternative payment model (APM) participants
- $32.8409 for non-qualifying APM participants.
The temporary 2.5% CF increase enacted for CY 2026 expires at the end of the year resulting in an immediate 2.5% cut in CY 2027 under current law.
Treatment Delivery Codes
CMS is proposing an important revision to the valuation of the revised radiation treatment delivery codes (CPT codes 77402, 77407 and 77412).
CMS used actual 2026 claims data and found that CPT 77412 accounted for approximately 18% of treatment delivery volume—substantially lower than the 35% utilization assumption used when the codes were valued for 2026. As a result, CMS proposes to recalculate the practice expense and malpractice RVUs for these services using observed utilization patterns while maintaining overall budget neutrality for the code family.
While treatment delivery codes 77402, 77407 and 77412 would see big payment gains of 23.11%, 7.73% and 21.81%, respectively, ASTRO is concerned about the dropping values for planning, management, SBRT and other codes (see chart below).
ASTRO will continue advocating with CMS to build upon proposed gains in the treatment delivery codes while supporting other vital radiation therapy services and working to advance ROCR in Congress this year.
Frequently Billed Radiation Oncology Codes Impact Table
| CPT Code | 2027 Short Descriptor | MOD | 2026 Total RVUs | 2026 Payment Rate | 2027 Proposed Total NF RVUs | 2027 Proposed Payment Rate | RVU % Difference | Payment Rate % Difference using non-qualifying APM CF |
|---|---|---|---|---|---|---|---|---|
| 77402 | Radiation tx delivery lvl 1 | 2.38 | $79.49 | 2.98 | $97.87 | 25.21% | 23.11% | |
| 77407 | Radiation tx delivery lvl 2 | 9.51 | $317.64 | 10.42 | $342.20 | 9.57% | 7.73% | |
| 77412 | Radiation tx delivery lvl 3 | 11.72 | $391.46 | 14.52 | $476.85 | 23.89% | 21.81% | |
| 77427 | Radiation tx management x5 | 5.89 | $196.73 | 5.73 | $188.18 | -2.72% | -4.35% | |
| 77431 | Radiation therapy management | 3.21 | $107.22 | 3.14 | $103.12 | -2.18% | -3.82% | |
| 77301 | Radiotherapy dose plan IMRT | 26 | 12.63 | $421.85 | 12.3 | $403.94 | -2.61% | -4.25% |
| 77263 | Ther radiology tx plng cplx | 5.07 | $169.34 | 4.96 | $162.89 | -2.17% | -3.81% | |
| 77334 | Radiation treatment aid(s) | 26 | 1.82 | $60.79 | 1.77 | $58.13 | -2.75% | -4.38% |
| 99205 | Office/outpatient new high mdm 60 minutes | 7.09 | $236.81 | 6.91 | $226.93 | -2.54% | -4.17% | |
| 77338 | Design mlc device for IMRT | 14.34 | $478.97 | 13.73 | $450.91 | -4.25% | -5.86% | |
| 77338 | Design mlc device for IMRT | 26 | 6.78 | $226.46 | 6.6 | $216.75 | -2.65% | -4.29% |
| 77435 | SBRT management | 19.31 | $644.97 | 18.84 | $618.72 | -2.43% | -4.07% | |
| 77300 | Radiation therapy dose plan | 2.02 | $67.47 | 1.93 | $63.38 | -4.46% | -6.06% | |
| 77300 | Radiation therapy dose plan | 26 | 0.98 | $32.73 | 0.96 | $31.53 | -2.04% | -3.68% |
