ACRO Submits Comments to CMS on Proposed Rules

Last week, the American College of Radiation Oncology submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2026 Physician Fee Schedule (CMS-1832-P), as well as the CY 2026 Hospital Outpatient Prospective Payment System Proposed Rule (CMS-1834-P).

The first letter (CMS-1832-P) offers comments and recommendations on the following issues:

• Appropriate APC Placement for Treatment Delivery Codes (77402, 77407, 77412)
• Use of OPPS data to set PFS rates
• Updates to the Indirect Practice Expense (PE) Methodology
• Removal of 77427 from the Telehealth List
• Undervaluation of conversion factor due to G2211 Assumption
• Efficiency Adjustment
• Valuation of Imaging Guidance for Proton Beam Treatment Delivery (CPT codes 77520, 77522, 77523, and 77525)

The second letter (CMS-1834-P) offers comments on:

• Appropriate APC Placement for Treatment Delivery Codes (77402, 77407, 77412)
• BgRT

As noted in the letters, “ACRO’s comments seek to ensure ongoing access to high-quality, state-of-the-art radiation oncology services. Maintaining patient access is crucial to quality healthcare delivery since most of our patients require services five days a week for many weeks of life-saving therapy. Patient accessibility and continuity through a complete course of therapy are key components of the care continuum. We hope our comments highlight our sincere interest in making radiation oncology services cost-effective, fairly reimbursed, and readily accessible to cancer patients. We look forward to continuing to work with CMS to guarantee quality oncology services can be provided by our specialty to every Medicare patient.”