ACRO Statement on 2026 Hospital Outpatient PPS Final Rule

The following is a message from the American College of Radiation Oncology's Government Relations & Economics Committee (GREC):

On November 21, the 2026 Hospital Outpatient Prospective Payment System (OPPS) Final Rule was published on the Federal Register Public Inspection page. As stated in our comment letter to the 2026 OPPS Proposed Rule, the College had serious concerns regarding the improper placement of radiation treatment delivery services in inappropriately low APCs. As ACRO noted in our November 6 statement on the 2026 Physician Fee Schedule (PFS) Final Rule, the College believed by inference from the OPPS to PFS crosswalk contained in the 2026 PFS Final Rule that a correction had been made. We are pleased to note that in the 2026 OPPS Final Rule that corrections indeed have been made to critical radiation treatment delivery service APCs. In ACRO’s comment letter to the 2026 OPPS Proposed Rule, ACRO found that CMS used the deleted IMRT codes (77385 and 77386) to set the payment rate for APC 5623, notwithstanding that the new IMRT codes (77407 and 77412) were being placed in APC 5622. As such, ACRO requested that CMS adjust the APCs in the 2026 OPPS Final Rule to better reflect cost and clinical rationales described in ACRO’s comment letter. In the 2026 OPPS Final Rule, CMS states, “[w]e agree with commenters that the proposed APC assignments and the resulting payment rates for CPT codes 77407 and 77412 could more properly account for the revisions made to those codes and that the geometric mean costs of CPT codes 77385 ($568) and 77386 ($634) should be considered when assigning the appropriate APC for these codes.” As a result of updated crosswalking of claims by CMS, 77412 has been assigned to the higher 5623 APC and, while 77407 will maintain its 5622 APC placement, CMS notes, “as a result of the crosswalk …. the payment rate for that APC is much greater than it was in the CY 2026 OPPS/ASC proposed rule.”

These changes are reflected in the table below.While ACRO believes the updated reimbursement for this new code set, as well as the OPPS to PFS crosswalk contained in the 2026 PFS Final Rule, will provide better reimbursement stability for radiation oncologists, we continue to support radiation oncology case rate legislation as part of a broader effort to remove high-cost equipment and supplies from the Medicare Physician Fee Schedule. The College appreciates CMS’ acknowledgement that the PFS does not properly value medical supplies and equipment and reiterates that the Physician Fee Schedule was not built for high-cost supplies and equipment. ACRO urges Congress to work with CMS to enact legislation to provide permanent stability to providers of radiation oncology services.