Radiation Oncology Fee Schedule Changes

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Ron’s Perspective

Jump to: Current Status ↓

A Reimbursement Problem Becoming an Access Problem

Radiation oncology is facing a reimbursement challenge that extends well beyond administrative complexity. Current fee schedule gaps are shaping whether treatment centers remain operationally viable, how patients are scheduled, and whether services remain accessible — particularly in community and rural markets.

Approximately 60% of cancer patients require radiation therapy at some point in their treatment journey. When reimbursement fails to support the cost of care delivery, access erodes — gradually at first, then quickly.

This is not cost containment. It is a quiet withdrawal of access by attrition — and in parts of the country, it is already underway. Practices cannot sustain advanced linear accelerators, physics coverage, QA programs, and clinical staffing on rates that don’t approach the cost of the treatment they nominally pay for.

Ron DiGiaimo, MBA, FACHE — Chairman, R3 • CEO, RC Billing

Radiation oncology is not standing still — but payment models often are.

Clinical advancements, including hypofractionation and improved image guidance, are reducing treatment burden for patients and improving outcomes. These are meaningful gains. But in a fee-for-service structure, fewer treatments per patient also means reduced revenue per patient — which compounds the pressure already created by inadequate Medicaid reimbursement.

What used to be sustainable at twelve to fifteen patients on treatment now often requires twenty or more just to maintain a center, with margins at or near break-even. That math is difficult in any setting. In rural and community markets, it is often impossible.

This is not about doing less for patients. It is about ensuring the system supports doing the right thing. The clinical progress this specialty has made is real. The payment infrastructure needs to catch up.

States cannot continue to defer correction. When access erodes in a community — especially underserved communities — rebuilding it is substantially harder than holding onto it. That is the urgency here, and why I am raising this flag now.

Ron DiGiaimo, MBA FACHE Chairman, R3 • CEO, RC Billing • [email protected] • LinkedIn

Featured Analysis — RCCS Newsroom

“Fee schedules aren’t passive documents. They drive decisions about whether a service line stays viable, whether a center keeps investing in technology and people, whether capacity stays open, and whether patients can get treatment close to home.”

Read the Full Analysis →

Current Status

Jump to: Rate Data ↓

What We Know — and What Is Still Evolving

Confirmed

The January 1, 2026 coding transition consolidated treatment delivery into 77402, 77407, and 77412, and image guidance into 77387 — with materially changed definitions that required payers to rebuild fee schedules and retest claims processing.
Ron’s research now spans 40+ states and the District of Columbia, with documented Medicaid rates compared against locality-specific Medicare benchmarks for each state’s largest city.
The majority of state Medicaid programs have not properly updated their fee schedules for the 2026 restructuring. Many carry rate effective dates from 2014–2023, and Rhode Island’s delivery code rates date to 1996.
Complexity inversions — where higher-complexity codes pay less than lower-complexity codes — have been documented in at least seven states (AK, AZ, KS, NH, NV, NY, NC, VA), a direct artifact of mapping old dollar amounts onto redefined codes.
Three states (MO, MT, UT in part) effectively do not cover one or more delivery codes through their physician fee schedules. Missouri lists all three delivery codes as “Noncovered” with an effective date of 1992.
Formal outreach letters have been submitted to Medicaid agencies in 35 states, with positive outcomes in Oregon (missing codes corrected retroactive to 1/1/26) and Connecticut (77407 up 225%, 77412 up 295% effective 7/1/26).

Still Developing

Agency responses to formal outreach letters — some states (California) indicating correction timelines extending into 2027.
New Jersey rates are proposed pending CMS approval; the most recent figures (August 2026) show meaningful increases but are not yet final.
Colorado and Indiana Medicaid rates remain pending confirmation.
Administrative implementation lags: even states that did update took 1–8 months to load new codes into claims systems.
Codes carried as “By Report,” “Individual Consideration,” or technical-component-only in MA, NJ (77387), and NM (77387), leaving practices without a predictable payment floor.

This is not a single-state issue. It is a national payer-readiness issue playing out state by state.

State-Level Data

Jump to: Advocacy Outcomes ↓

Medicaid vs. Medicare: Rate Comparison by State

Current Medicaid FFS reimbursement rates for the primary radiation oncology codes, compared against Medicare benchmarks. Medicaid rates are statewide; Medicare figures are locality-adjusted for each state’s largest city. Rates verified August–September 2026 from state fee schedule portals and FastRVU (third-party Medicare calculator).

State	77387 (IGRT)	77402 (Lvl 1)	77407 (Lvl 2)	77412 (Lvl 3)
Alabama	$24.07 (26)	$50.18	$189.42	$272.53
Alaska	$181.83	$199.78	$362.93	$344.52 ↓
Arizona (AHCCCS)	$46.37 (26)	$136.92	$248.65	$236.04 ↓
Arkansas (R9)	$44.27	$148.37	$350.11	$431.53
California	$0	$42.40	$38.77	$43.20
Colorado	Pending	Pending	Pending	Pending
Connecticut	$28.54	$66.43	$250.57 ↑	$358.52 ↑
Delaware	Not in sched.	Not in sched.	Not in sched.	Not in sched.
Dist. of Columbia	$32.01	$77.40	$292.00	$417.90
Florida	$46.17	$87.04	$149.00	$158.42
Georgia	Not listed	$60.65	$71.21	$79.51
Hawaii	Not listed	$58.71	$68.94	$76.99
Idaho	$30.12	$65.05	$245.61	$351.68
Illinois	$25.11	$52.82	$199.01	$284.54
Indiana	Pending	Pending	Pending	Pending
Iowa	$63.51	$60.41	$70.96	$79.25
Kansas	$16.32 (26)	$87.42	$62.57 ↓	$129.60
Kentucky	$35.21	$62.78	$250.89	$309.19
Louisiana	$29.67	$61.85	$233.29	$333.81
Maine	Not listed	$54.58	$206.03	$294.94
Maryland	$38.29	$85.35	$120.70 *	$139.45 *
Massachusetts	All codes: “Individual Consideration” — no fixed rate
Michigan	$23.22	$52.40	$197.66	$282.86
Minnesota	$27.53	$64.58	$244.43	$350.18
Mississippi	$30.94	$63.59	$239.97	$343.46
Missouri	$29.71	Noncovered	Noncovered	Noncovered
Montana	$49.91 (26)	Not listed	Not listed	Not listed
Nebraska	$281.31 *	$116.54	$143.68	$169.40
Nevada	$41.20	$147.79	$268.35	$254.74 ↓
New Hampshire	$63.45	$63.32	$74.72	$48.17 ↓
New Jersey	By Report	$42.62	$160.79	$230.08
New Mexico	$0	$78.55	$92.24	$102.63
New York	$71.10	$98.20	$166.27	$151.45 ↓
North Carolina	$83.15	$95.88	$150.37	$145.65 ↓
North Dakota ✓	$40.18	$92.00	$346.95	$497.15
Ohio	$53.31	$66.79	$145.01	$137.66 ↓
Oklahoma	$32.61	$68.63	$258.94	$370.62
Oregon ✓	$29.52	$64.83	$258.88	$319.07
Pennsylvania	$79.54	$60.36	$227.68	$325.80
Rhode Island	Not listed	$37.36	$44.17	$48.00
South Carolina	$82.57	$58.87	$203.24	$290.87
South Dakota ✓	$35.74	$81.72	$308.63	$442.01
Tennessee	No FFS physician fee schedule — TennCare is 100% managed care
Texas	$60.68	Delivery codes: Not Payable for physicians (TC only: $69/$260/$373 ages 0–20)
Utah	$34.80	Non-covered	Non-covered	$408.10
Vermont	$30.69	$67.25	$268.44	$330.87
Virginia	$31.54	$120.91	$219.55	$208.42 ↓
Washington	$21.79	$51.79	$195.50	$279.77
West Virginia	$25.38	$52.46	$197.64	$282.55
Wisconsin	$28.14	$62.62	$236.51	$338.73
Wyoming	$32.83	$80.88	$285.41	$351.77
Medicare PFS (nat’l non-fac.)	$36.74 (26)	$79.49	$317.64	$391.46
Medicare HOPPS (nat’l)	--	$104.24	$394.05	$564.51

Key: (26) = professional component only. ↓ = complexity inversion. ↑ = rate increased since 1/1/2026. * = flagged anomaly (see below). Green rows = rates at or above Medicare. Medicare from FastRVU (third-party calculator, not CMS PFS Lookup).

Flagged: NE 77387 ($281.31) is 804% of Medicare — stale valuation from a predecessor code. MD 77407/77412 at ~36%/~29% of Medicare vs. ~97% for 77402 in the same file — not updated for 2026. OH applied a uniform 5% cut without recalculating against new definitions. NH 77412 at $48.17 (10.4% of Medicare) is the most severe underpayment found. RI rates date to 9/9/1996. MO delivery codes “Noncovered” since 1/1/1992. IA rates unchanged since 2018–2020. VA delivery codes effective 7/1/2014. WY 77402 effective 1/1/2017. NJ rates are August 2026 proposed (pending CMS approval).

Advocacy Outcomes

Jump to: Impact Assessment ↓

Where Advocacy Is Already Working

Engagement produces results. Four states demonstrate what correction and best practice look like — and serve as reference points for the agencies still under review.

✓ Advocacy Win — Oregon

Oregon Health Authority confirmed that CPT codes 77402 and 77407 were unintentionally omitted from their fee schedule. Rates of $64.83 (77402) and $258.88 (77407) are now payable, retroactive to January 1, 2026.

✓ Advocacy Win — Connecticut

Connecticut enacted substantial rate increases effective 7/1/2026: 77407 from $77.15 to $250.57 (+225%) and 77412 from $90.87 to $358.52 (+295%). The 77387 technical component was simultaneously dropped from the schedule, mirroring Medicare’s bundling policy.

✓ Model State — South Dakota

South Dakota Medicaid rates at or above Medicare benchmarks for all four codes. Ron submitted a formal commendation letter to Division Director Heather Petermann on May 27, 2026.

✓ Model State — North Dakota

North Dakota maintains rates at approximately 112% of Medicare across all four codes, reflecting a coherent annual update process tied to current Medicare RVUs with a 2% inflationary increase — a second strong reference point alongside South Dakota.

Impact Assessment

Jump to: Get Involved ↓

Implications for the Industry

Radiation oncology carries a high fixed-cost delivery model. Linear accelerators, imaging systems, QA infrastructure, physics coverage, and clinical staffing represent substantial, non-discretionary investment. Fee schedules that fail to approach cost create a compounding operational problem — not an administrative one.

Financial Viability

Practices cannot absorb ongoing operational costs at current reimbursement levels in many states
Capital investment in equipment cannot be sustained
Hypofractionation — while clinically superior — reduces sessions and compounds per-patient revenue loss
Community and rural centers are most exposed

Operational Pressure

Reduced treatment capacity as centers manage financial strain
Delayed patient scheduling and longer wait times
Staffing constraints and difficulty sustaining clinical teams
Reduced ability to invest in targeting technology

Patient Access

Reduced provider participation in Medicaid networks
Closure risk in rural and community settings
Increased travel burden for patients
Downstream cost increases to payers from unmanaged disease progression
Access erosion is gradual: delays, then fewer options, then loss of local care

Get Involved

Jump to: Letters ↓

Follow the Work & Join the Effort

Ron is actively engaging state Medicaid agencies and calling on providers, administrators, and industry organizations to add their voice.

Follow Ron on LinkedIn

Ron is posting ongoing developments, state-specific findings, and calls to action as this issue evolves.

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Watch This Page

This resource is updated as new state data, agency responses, and advocacy materials become available. Bookmark it and share the URL with colleagues who should be engaged.

Sample Advocacy Letters

Ron has drafted state-specific letters to Medicaid agency directors documenting rate disparities and requesting immediate review. Copyable templates for 35 states are available below.

View Sample Letters ↓

Contact Ron Directly

Providers or organizations experiencing issues with the 2026 code transition, Medicaid rate disputes, or commercial payer misalignment are welcome to reach out.

[email protected] →

Advocacy Letters

Jump to: Updates Feed ↓

Sample Letters to State Medicaid Agencies

The following are Ron’s letters to Medicaid agency leadership. Adapt the bracketed fields for your organization before sending. Letters reflect data available at time of submission (April–May 2026); the rate table above contains the most current verified figures.

AL AR AZ CO CT DC FL GA HI ID IN KS LA MA ME MI MT NC NE NH NJ NM NY OR ✓RI SC SD ✓TX UT VA VT WA WI WV WY

Alabama

Alabama Medicaid Agency - Commissioner

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Alabama Medicaid Agency Commissioner
[Verify current commissioner name and contact information before submitting]

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Alabama to express grave concern regarding the current Alabama Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the financial viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Alabama beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services.

The current Alabama rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): $24.07
  * CPT 77402 (Level 1): $50.18
  * CPT 77407 (Level 2): $189.42
  * CPT 77412 (Level 3): $272.53

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these reimbursement levels, practices cannot absorb ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Alabama patients in many communities.

By comparison, national Medicare benchmarks for these same services - updated effective January 1, 2026, under the revised CPT coding structure - are substantially higher and reflect the true resources involved:

  * CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility); commercial payers often reimburse $100-$130
  * CPT 77402 (Level 1): approximately $79.49 (PFS non-facility) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS non-facility) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS non-facility) to $564.51 (HOPPS)

Alabama's rates are materially lower than Medicare's, creating an untenable disparity. These national rates, while not extravagant, at least allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment.

The situation is urgent. Radiation therapy is a cornerstone of curative and palliative cancer care - approximately 60% of cancer patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Alabama Medicaid networks, reduces geographic access (particularly in underserved areas), and risks poorer survival outcomes and increased downstream costs to the state from unmanaged disease progression.

We respectfully request that your team immediately review and align Alabama Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks - or a reasonable cost-based equivalent - to ensure continued access to these critical services.

We are available to provide additional data, cost analyses, or meet with your team to discuss this matter promptly. Thank you for your immediate attention to this critical patient-access issue.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Verify the current Alabama Medicaid commissioner before submitting.

Arkansas

Arkansas DHS - Deputy Secretary and Medicaid Director

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Janet Mann, Deputy Secretary and Medicaid Director
Arkansas Department of Human Services
112 West 8th Street, Slot S401
Little Rock, AR 72201-4608
janet.h.mann@dhs.arkansas.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Arkansas to express grave concern regarding the current Arkansas Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the financial viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Arkansas beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services.

The current Arkansas rates for the revised radiation treatment codes are as follows:

  * CPT 77402 (Level 1): $148.37
  * CPT 77407 (Level 2): $269.46
  * CPT 77412 (Level 3): $255.79

Of particular concern, the Level 3 delivery rate ($255.79) is lower than the Level 2 rate ($269.46), which does not reflect the substantially greater resources required for complex treatment delivery.

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these reimbursement levels, practices cannot absorb ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Arkansas patients in many communities.

By comparison, national Medicare benchmarks for these same services - updated effective January 1, 2026, under the revised CPT coding structure - are substantially higher and reflect the true resources involved:

  * CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility); commercial payers often reimburse $100-$130
  * CPT 77402 (Level 1): approximately $79.49 (PFS non-facility) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS non-facility) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS non-facility) to $564.51 (HOPPS)

Arkansas's rates are materially lower than Medicare's, creating an untenable disparity. These national rates, while not extravagant, at least allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment.

The situation is urgent. Radiation therapy is a cornerstone of curative and palliative cancer care - approximately 60% of cancer patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Arkansas Medicaid networks, reduces geographic access (particularly in underserved areas), and risks poorer survival outcomes and increased downstream costs to the state from unmanaged disease progression.

We respectfully request that your team immediately review and align Arkansas Medicaid payment rates for CPT codes 77402, 77407, and 77412 with national Medicare benchmarks - or a reasonable cost-based equivalent - to ensure continued access to these critical services.

We are available to provide additional data, cost analyses, or meet with your team to discuss this matter promptly. Thank you for your immediate attention to this critical patient-access issue.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: Janet Mann - [email protected]. Key: inverted rate structure (77412 < 77407).

Arizona

Arizona AHCCCS - Interim Medicaid Director

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Roberta Harrison, Interim Medicaid Director
State of Arizona, Arizona Health Care Cost Containment System
150 N. 18th Ave.
Phoenix, AZ 85007
roberta.harrison@azahcccs.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Arizona to express grave concern regarding the current Arizona Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the financial viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Arizona beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services.

The current Arizona rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): By Report - no defined rate
  * CPT 77402 (Level 1): $136.92
  * CPT 77407 (Level 2): $248.65
  * CPT 77412 (Level 3): $236.04

Of particular concern, CPT 77387 is listed as reimbursable only "By Report" with no defined rate, and the Level 3 rate ($236.04) is lower than the Level 2 rate ($248.65).

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these reimbursement levels, practices cannot absorb ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Arizona patients in many communities.

By comparison, national Medicare benchmarks for these same services - updated effective January 1, 2026, under the revised CPT coding structure - are substantially higher and reflect the true resources involved:

  * CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility); commercial payers often reimburse $100-$130
  * CPT 77402 (Level 1): approximately $79.49 (PFS non-facility) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS non-facility) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS non-facility) to $564.51 (HOPPS)

Arizona's rates are materially lower than Medicare's, creating an untenable disparity. These national rates, while not extravagant, at least allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment.

The situation is urgent. Radiation therapy is a cornerstone of curative and palliative cancer care - approximately 60% of cancer patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Arizona Medicaid networks, reduces geographic access (particularly in underserved areas), and risks poorer survival outcomes and increased downstream costs to the state from unmanaged disease progression.

We respectfully request that your team immediately review and align Arizona Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks - or a reasonable cost-based equivalent - to ensure continued access to these critical services.

We are available to provide additional data, cost analyses, or meet with your team to discuss this matter promptly. Thank you for your immediate attention to this critical patient-access issue.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: Roberta Harrison - [email protected]. Key: 77387 "By Report" + inverted rate structure.

Colorado

Health First Colorado - Medicaid Director

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Adela Flores-Brennan, Medicaid Director
Health First Colorado
State of Colorado, Department of Health Care Policy and Financing
1570 Grant Street
Denver, CO 80203-1818
Adela.Flores-Brennan@state.co.us

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Colorado to express grave concern regarding the current Colorado Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the financial viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Colorado beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services.

The current Colorado rates for the revised radiation treatment codes are as follows:

  * CPT 77402 (Level 1): $57.99
  * CPT 77407 (Level 2): $68.35
  * CPT 77412 (Level 3): $116.10

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these reimbursement levels, practices cannot absorb ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Colorado patients in many communities.

By comparison, national Medicare benchmarks for these same services - updated effective January 1, 2026, under the revised CPT coding structure - are substantially higher and reflect the true resources involved:

  * CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility); commercial payers often reimburse $100-$130
  * CPT 77402 (Level 1): approximately $79.49 (PFS non-facility) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS non-facility) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS non-facility) to $564.51 (HOPPS)

Colorado's rates are materially lower than Medicare's, creating an untenable disparity. These national rates, while not extravagant, at least allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment.

The situation is urgent. Radiation therapy is a cornerstone of curative and palliative cancer care - approximately 60% of cancer patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Colorado Medicaid networks, reduces geographic access (particularly in underserved areas), and risks poorer survival outcomes and increased downstream costs to the state from unmanaged disease progression.

We respectfully request that your team immediately review and align Colorado Medicaid payment rates for CPT codes 77402, 77407, and 77412 with national Medicare benchmarks - or a reasonable cost-based equivalent - to ensure continued access to these critical services.

We are available to provide additional data, cost analyses, or meet with your team to discuss this matter promptly. Thank you for your immediate attention to this critical patient-access issue.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: Adela Flores-Brennan - [email protected]. CPT 77387 not in letter scope for CO.

Connecticut

CT Dept. of Social Services - Director, Div. of Health Services

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Bill Halsey, Director
Division of Health Services
Connecticut Department of Social Services
55 Farmington Avenue
Hartford, CT 06105
william.halsey@ct.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Connecticut to express grave concern regarding the current Connecticut Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the financial viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Connecticut beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services.

The current Connecticut rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): Not Listed / Manually Priced
  * CPT 77402 (Level 1): $62.65
  * CPT 77407 (Level 2): $77.15
  * CPT 77412 (Level 3): $90.87

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these reimbursement levels, practices cannot absorb ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Connecticut patients in many communities.

By comparison, national Medicare benchmarks for these same services - updated effective January 1, 2026, under the revised CPT coding structure - are substantially higher and reflect the true resources involved:

  * CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility); commercial payers often reimburse $100-$130
  * CPT 77402 (Level 1): approximately $79.49 (PFS non-facility) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS non-facility) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS non-facility) to $564.51 (HOPPS)

Connecticut's rates are materially lower than Medicare's, creating an untenable disparity. These national rates, while not extravagant, at least allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment.

The situation is urgent. Radiation therapy is a cornerstone of curative and palliative cancer care - approximately 60% of cancer patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Connecticut Medicaid networks, reduces geographic access (particularly in underserved areas), and risks poorer survival outcomes and increased downstream costs to the state from unmanaged disease progression.

We respectfully request that your team immediately review and align Connecticut Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks - or a reasonable cost-based equivalent - to ensure continued access to these critical services.

We are available to provide additional data, cost analyses, or meet with your team to discuss this matter promptly. Thank you for your immediate attention to this critical patient-access issue.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: Bill Halsey - [email protected]. NOTE: CT has since enacted major rate increases eff. 7/1/2026 (see rate table).

Washington DC

DC Medicaid - Senior Deputy Director

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Melisa Byrd, Senior Deputy Director / Medicaid Director
DC Medicaid
One Judiciary Square
441 4th Street, N.W.
Washington, DC 20001

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in DC to express grave concern regarding the current DC Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for DC beneficiaries.

The current DC rates for the revised radiation treatment codes are as follows:

  * CPT 77407 (Level 2): $292.00

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of DC Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Ron's letter scope covers 77407 only ($292.00); rates for other codes now confirmed in rate table above.

Florida

Florida AHCA - Deputy Secretary for Medicaid

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Brian Meyer, Deputy Secretary for Medicaid
Florida Agency for Health Care Administration
Brian.Meyer@ahca.myflorida.com

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Florida to express grave concern regarding the current Florida Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Florida beneficiaries.

The current Florida rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): $12.19 (professional component)
  * CPT 77407 (Level 2): $149.00
  * CPT 77412 (Level 3): $158.42

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Florida Medicaid payment rates for CPT codes 77387, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Adjust bracketed fields before sending.

Georgia

Georgia DCH - Exec. Director, Medical Assistance Plans

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Stuart Portman, Executive Director, Medical Assistance Plans
Georgia Department of Community Health
2 Peachtree Street, NW, Suite 36450
Atlanta, GA 30303
Stuart.Portman@dch.ga.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Georgia to express grave concern regarding the current Georgia Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Georgia beneficiaries.

The current Georgia rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): Not listed as payable
  * CPT 77402 (Level 1): $60.65
  * CPT 77407 (Level 2): $71.21
  * CPT 77412 (Level 3): $79.51

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Georgia Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: 77387 not listed as payable.

Hawaii

Hawaii DHS - Med-QUEST Division Administrator

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Meredith Nichols, Med-QUEST Division Administrator
Hawaii Department of Human Services
PO Box 700190
Kapolei, HI 96709-0190

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Hawaii to express grave concern regarding the current Hawaii Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Hawaii beneficiaries.

The current Hawaii rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): Not listed
  * CPT 77402 (Level 1): $58.71
  * CPT 77407 (Level 2): $68.94
  * CPT 77412 (Level 3): $76.99

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Hawaii Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Adjust bracketed fields before sending.

Idaho

Idaho DHW - Division Administrator for Medicaid

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Sasha O'Connell, Division Administrator for Medicaid
Idaho Department of Health and Welfare
450 West State Street, PTC Building, 10th Floor
Boise, ID 83705

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Idaho to express grave concern regarding the current Idaho Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Idaho beneficiaries.

The current Idaho rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): $24.93
  * CPT 77402 (Level 1): $108.33
  * CPT 77407 (Level 2): $196.79
  * CPT 77412 (Level 3): $186.81

Notably, the Level 3 rate ($186.81) is lower than the Level 2 rate ($196.79) - an inverted rate structure.

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Idaho Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Key: inverted rate structure (77412 < 77407).

Indiana

Indiana FSSA - Director of Medicaid

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Audrey Frenzel, Director of Indiana Medicaid
State of Indiana, Family and Social Services Administration
402 West Washington Street, Room W461, MS 25
Indianapolis, IN 46204

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Indiana to express grave concern regarding the current Indiana Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Indiana beneficiaries.

The current Indiana rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): $0
  * CPT 77402 (Level 1): $101.97
  * CPT 77407 (Level 2): $101.97 (same rate as Level 1)
  * CPT 77412 (Level 3): Not listed

The absence of 77412 from the fee schedule and the identical rates for 77402/77407 indicate the schedule has not been updated for the 2026 code definitions.

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Indiana Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Adjust bracketed fields before sending.

Kansas

KanCare - Medicaid Director

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Christine Osterlund, Medicaid Director
KanCare: Medicaid for Kansas
Division of Health Care Finance
900 SW Jackson Avenue, Suite 900
Topeka, KS 66612
Christine.Osterlund@ks.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Kansas to express grave concern regarding the current Kansas Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Kansas beneficiaries.

The current Kansas rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): $16.32
  * CPT 77402 (Level 1): $87.42
  * CPT 77407 (Level 2): $62.57
  * CPT 77412 (Level 3): $129.60

Notably, the Level 2 rate ($62.57) is lower than the Level 1 rate ($87.42) - an inverted rate structure.

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Kansas Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: inverted rate structure (77407 < 77402).

Louisiana

Louisiana LDH - Medicaid Executive Director

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Seth Gold, Medicaid Executive Director
Louisiana Department of Health, Bureau of Health Services Financing
628 North 4th Street
Baton Rouge, LA 70802

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Louisiana to express grave concern regarding the current Louisiana Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Louisiana beneficiaries.

The current Louisiana rates for the revised radiation treatment codes are as follows:

  * CPT 77387 (IGRT): $11.87
  * CPT 77402 (Level 1): $61.85
  * CPT 77407 (Level 2): $233.29
  * CPT 77412 (Level 3): $333.81

These rates do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

By comparison, national Medicare benchmarks - updated effective January 1, 2026 - are substantially higher:

  * CPT 77387 (professional component): approximately $36.74 (PFS non-facility)
  * CPT 77402 (Level 1): approximately $79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): approximately $317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): approximately $391.46 (PFS) to $564.51 (HOPPS)

Radiation therapy is a cornerstone of cancer care - approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces geographic access, and risks increased downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Louisiana Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Key: 77387 at $11.87 and 77402 at $61.85 fall far below Medicare benchmarks.

Massachusetts

MassHealth - Medicaid Director

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Mike Levine, Medicaid Director
MassHealth, Commonwealth of Massachusetts
1 Ashburton Place, 11th Floor
Boston, MA 02108
mike.levine@mass.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Massachusetts to express grave concern regarding the current Massachusetts Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Massachusetts beneficiaries.

Current Massachusetts rates:

  * CPT 77387: Individual Consideration - no fixed rate
  * CPT 77402: Individual Consideration - no fixed rate
  * CPT 77407: Individual Consideration - no fixed rate
  * CPT 77412: Individual Consideration - no fixed rate

These are mainstream, routine-use codes - "Individual Consideration" status is not a workable substitute for defined rates.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Massachusetts Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: all four codes are "Individual Consideration" with no fixed rates.

Maine

Maine DHHS - Director, Office of MaineCare Services

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Michelle Probert, Director, Office of MaineCare Services
State of Maine, Department of Health and Human Services
221 State Street
Augusta, ME 04333
michelle.probert@maine.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Maine to express grave concern regarding the current Maine Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Maine beneficiaries.

Current Maine rates:

  * CPT 77387 (IGRT): ~$20-$33
  * CPT 77402 (Level 1): ~$83-$119
  * CPT 77407 (Level 2): ~$159-$246
  * CPT 77412 (Level 3): ~$203-$326

Maine reimburses at approximately 72.4% of Medicare - compounding an already-inadequate Medicare baseline.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Maine Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: 72.4% of Medicare policy compounds an already-inadequate baseline.

Michigan

Michigan MDHHS - Medicaid Director

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Meghan Groen, Medicaid Director
Michigan Department of Health and Human Services
400 South Pine Street
Lansing, MI 48913
groenm2@michigan.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Michigan to express grave concern regarding the current Michigan Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Michigan beneficiaries.

Current Michigan rates:

  * CPT 77387 (IGRT): $23.22 (professional component)
  * CPT 77402-77412: Delivery code rates require verification

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Michigan Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Delivery code rates now confirmed in rate table above.

Montana

Montana DPHHS - Medical Director

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Rebecca deCamara, Medical Director
State of Montana DPHHS
111 North Sanders, PO Box 4210
Helena, MT 59604
rdecamara@mt.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Montana to express grave concern regarding the current Montana Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Montana beneficiaries.

Current Montana rates:

  * CPT 77387 (IGRT): $49.91 (PC) / $0 (TC)
  * CPT 77402 (Level 1): Not listed as payable
  * CPT 77407 (Level 2): Not listed as payable
  * CPT 77412 (Level 3): Not listed as payable

The absence of 77402, 77407, and 77412 as payable is critically damaging to access - these are the core treatment delivery codes.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Montana Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: three core delivery codes are not listed as payable.

North Carolina

NC Medicaid - Interim Deputy Secretary

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Melanie Bush, Interim Deputy Secretary, NC Medicaid
NC Medicaid Division of Health Benefits
1985 Umstead Drive, 2501 Mail Service Center
Raleigh, NC 27699-2501
melanie.bush@dhhs.nc.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in North Carolina to express grave concern regarding the current North Carolina Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for North Carolina beneficiaries.

Current North Carolina rates:

  * CPT 77387 (IGRT): $90.38
  * CPT 77402 (Level 1): $104.22
  * CPT 77407 (Level 2): $163.45
  * CPT 77412 (Level 3): $158.32

The Level 3 rate ($158.32) is lower than the Level 2 rate ($163.45) - an inverted rate structure.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of North Carolina Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: inverted rate structure (77412 < 77407).

Nebraska

Nebraska DHHS - Director of Medicaid

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Drew Gonshorowski, Director of Medicaid & Long Term Care
Nebraska DHHS
301 Centennial Mall South, 3rd Floor
Lincoln, NE 68509-5026
drew.gonshorowski@nebraska.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Nebraska to express grave concern regarding the current Nebraska Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for Nebraska beneficiaries.

Current Nebraska rates:

  * CPT 77402 (Level 1): $116.54
  * CPT 77407 (Level 2): $143.68
  * CPT 77412 (Level 3): $169.40

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of Nebraska Medicaid rates for CPT codes 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. CPT 77387 not in letter scope for NE.

New Hampshire

New Hampshire DHHS - Medicaid Director

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Henry Lipman, Medicaid Director
New Hampshire DHHS
129 Pleasant Street
Concord, NH 03301-6521
henry.lipman@dhhs.nh.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in New Hampshire to express grave concern regarding the current New Hampshire Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for New Hampshire beneficiaries.

Current New Hampshire rates:

  * CPT 77402 (Level 1): $63.32
  * CPT 77407 (Level 2): $74.72
  * CPT 77412 (Level 3): $48.17

The Level 3 rate ($48.17) is lower than the Level 1 rate ($63.32) - the complete pricing order is reversed, strongly suggesting the fee schedule has not been updated for the 2026 code definitions.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of New Hampshire Medicaid rates for CPT codes 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: complete pricing inversion (Lvl 3 < Lvl 1). Most severe underpayment in the dataset.

New Jersey

NJ DMAHS - Assistant Commissioner

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Greg Woods, Assistant Commissioner
Division of Medical Assistance & Health Services
State of New Jersey Department of Human Services
PO Box 712
Trenton, NJ 08625-0712

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in New Jersey to express grave concern regarding the current New Jersey Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for New Jersey beneficiaries.

Current New Jersey rates:

  * CPT 77387 (IGRT): By Report - no defined rate
  * CPT 77402 (Level 1): $21 (Technical Component only)
  * CPT 77407 (Level 2): $21 (Technical Component only)
  * CPT 77412 (Level 3): $41 (Technical Component only)

No professional component rates are defined for the delivery codes.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of New Jersey Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

NOTE: NJ has since proposed significant rate increases (Aug 2026, pending CMS approval). See rate table for current proposed figures.

New Mexico

New Mexico HCA - Medicaid Director

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Alanna Dancis, Medicaid Director
New Mexico Health Care Authority
alanna.dancis@hca.nm.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in New Mexico to express grave concern regarding the current New Mexico Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for New Mexico beneficiaries.

Current New Mexico rates:

  * CPT 77387 (IGRT): $0
  * CPT 77407 (Level 2): $92.24
  * CPT 77412 (Level 3): $102.63

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of New Mexico Medicaid rates for CPT codes 77387, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: 77387 at $0 and delivery rates far below Medicare.

New York

New York DOH - Medicaid Director

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Amir Bassiri, Medicaid Director / Deputy Commissioner
New York State Department of Health
Empire State Plaza, Corning Tower, Room 1466
Albany, NY 12237
Amir.Bassiri@health.ny.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in New York to express grave concern regarding the current New York Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. These rates are unsustainable and place timely access to care at serious risk for New York beneficiaries.

Current New York rates:

  * CPT 77387 (IGRT): $71.10 Global / $10.08 Professional
  * CPT 77402 (Level 1): $98.20
  * CPT 77407 (Level 2): $166.27
  * CPT 77412 (Level 3): $151.45

The Level 3 rate ($151.45) is lower than the Level 2 rate ($166.27) - an inverted rate structure.

These rates do not cover the actual costs of delivering radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation, reduces access, and increases downstream costs from unmanaged disease progression.

We respectfully request immediate review and alignment of New York Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: inverted rate structure (77412 < 77407).

Oregon ✓ Win

Oregon Health Authority - Medicaid Director

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Emma Sandoe, Medicaid Director
Oregon Health Authority
500 Summer Street, NE E49
Salem, OR 97301
emma.sandoe@odhsoha.oregon.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Oregon to express grave concern regarding the current Oregon Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Oregon beneficiaries.

Current Oregon rates:

  * CPT 77387 (IGRT): $29.52
  * CPT 77402 (Level 1): $64.83 (confirmed payable May 2026)
  * CPT 77407 (Level 2): $258.88 (confirmed payable May 2026)
  * CPT 77412 (Level 3): $319.07

Note: Oregon confirmed 77402 and 77407 were unintentionally omitted and are now payable retroactive to 1/1/26. This letter continues to advocate for rate adequacy.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Oregon Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Oregon confirmed missing codes now payable retroactive to 1/1/26. This letter advocates for continued rate adequacy.

Rhode Island

Rhode Island EOHHS - Asst. Secretary and Medicaid Director

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Kristin Sousa, Assistant Secretary and Medicaid Director
RI Department of Human Services, EOHHS
3 West Road, Virks Building
Cranston, RI 02920
kristin.sousa@ohhs.ri.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Rhode Island to express grave concern regarding the current Rhode Island Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Rhode Island beneficiaries.

Current Rhode Island rates:

  * CPT 77387 (IGRT): Not listed as payable
  * CPT 77402 (Level 1): $37.36
  * CPT 77407 (Level 2): $44.17
  * CPT 77412 (Level 3): $48.00

These delivery rates of $37-$48 represent approximately 10-15% of Medicare benchmarks.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Rhode Island Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected]. Key: delivery rates are 10-15% of Medicare. RI rates date to 9/9/1996.

South Carolina

SC Healthy Connections Medicaid - Medicaid Director

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Eunice Medina, Medicaid Director
South Carolina Healthy Connections Medicaid
PO Box 8206
Columbia, SC 29201-8206
Eunice.Medina@scdhhs.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in South Carolina to express grave concern regarding the current South Carolina Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for South Carolina beneficiaries.

Current South Carolina rates:

  * CPT 77387 (IGRT): $82.57 global / $24.77 PC
  * CPT 77402 (Level 1): $98.04
  * CPT 77407 (Level 2): $154.02
  * CPT 77412 (Level 3): $149.12

The Level 3 rate ($149.12) is lower than the Level 2 rate ($154.02) - an inverted rate structure.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of South Carolina Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected].

South Dakota ✓ Win

South Dakota DSS - Division Director

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Heather Petermann, Division Director
South Dakota Department of Social Services
700 Governors Drive, Kneip Building
Pierre, SD 57501-2291
DSSInfo@state.sd.us

Re: Thank You for Supporting Radiation Oncology Access

Dear Division Director:

I am writing to express sincere appreciation for South Dakota's current reimbursement rates for essential radiation oncology services. While inadequate rates threaten access across the country, South Dakota has taken a commendable stance that serves as a meaningful example to other states.

Current South Dakota rates:

  * CPT 77387 (IGRT): $35.74
  * CPT 77402 (Level 1): $81.72
  * CPT 77407 (Level 2): $308.63
  * CPT 77412 (Level 3): $442.01

These rates are at or above national Medicare benchmarks - a distinction that places South Dakota among a very small number of state Medicaid programs adequately supporting radiation oncology access.

South Dakota's commitment to cancer patients is acknowledged, appreciated, and should serve as a positive model for other states.

Thank you for your continued leadership on this patient-access issue.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

South Dakota rates are at or above Medicare - this is a commendation letter.

Texas

Texas HHSC - Medicaid Director

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[Texas Medicaid Director]
Texas Health and Human Services Commission
[Verify current director name before submitting]

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Texas to express grave concern regarding the current Texas Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Texas beneficiaries.

Current Texas rates:

  * CPT 77387 (IGRT): $16.31 (PC) / $44.11 (TC)
  * CPT 77402 (Level 1): Not Payable for physician services
  * CPT 77407 (Level 2): Not Payable for physician services
  * CPT 77412 (Level 3): Not Payable for physician services

The "Not Payable for physician services" designation for delivery codes is a severe barrier to provider participation.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Texas Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Verify the current Texas Medicaid director before submitting. Key: delivery codes listed as Not Payable for physicians.

Utah

Utah DOH Medicaid - Medicaid Director

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Julie Ewing, Medicaid Director
Utah Department of Health Medicaid
PO Box 143101
Salt Lake City, UT 84114

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Utah to express grave concern regarding the current Utah Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Utah beneficiaries.

Current Utah rates:

  * CPT 77387 (IGRT): $29.05
  * CPT 77402 (Level 1): Not listed
  * CPT 77407 (Level 2): Not listed
  * CPT 77412 (Level 3): $56.39 / $63.16 (rural)

The absence of 77402 and 77407 is critically damaging - these represent the majority of treatment volume.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Utah Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Key: 77402 and 77407 absent from fee schedule; 77412 dramatically below Medicare benchmarks.

Virginia

Virginia DMAS - Director of Virginia Medicaid

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Steve Ford, Director of Virginia Medicaid
Virginia Department of Medical Assistance Services
600 East Broad Street
Richmond, Virginia 23219

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Virginia to express grave concern regarding the current Virginia Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Virginia beneficiaries.

Current Virginia rates:

  * CPT 77407 (Level 2): $219.55 (effective dates 2014-9999)
  * CPT 77412 (Level 3): $208.42 (effective dates 2014-9999)

These rates carry effective dates of 2014 and do not reflect the 2026 code definitions.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Virginia Medicaid rates for CPT codes 77407 and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Key: effective dates of 2014 on current rates, predating the 2026 restructuring by over a decade.

Vermont

Vermont AHS - Medicaid Director

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Jill Mazza Olson, Medicaid Director
Vermont Agency of Human Services
280 State Drive
Waterbury, VT 05671

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Vermont to express grave concern regarding the current Vermont Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Vermont beneficiaries.

Current Vermont rates:

  * CPT 77387 (IGRT): $30.69
  * CPT 77402 (Level 1): $67.25
  * CPT 77407 (Level 2): $268.44
  * CPT 77412 (Level 3): $330.87

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Vermont Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

All four rates are below Medicare benchmarks.

Washington

WA State Health Care Authority - Director

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Trinity Wilson, Director
Washington State Health Care Authority
626 8th Avenue, PO Box 45502
Olympia, WA 98504-5050
trinity.wilson@hca.wa.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Washington to express grave concern regarding the current Washington Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Washington beneficiaries.

Current Washington rates:

  * CPT 77387 (IGRT): $21.12 (PFS) / Bundled TC
  * CPT 77402 (Level 1): $50.09
  * CPT 77407 (Level 2): $188.97
  * CPT 77412 (Level 3): $270.46

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Washington Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected].

Wisconsin

Wisconsin DHS - Medicaid Director

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Amanda Dreyer, Medicaid Director
Wisconsin Department of Health Services
1 West Wilson Street, Room 350
Madison, WI 53701-0309

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Wisconsin to express grave concern regarding the current Wisconsin Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Wisconsin beneficiaries.

Current Wisconsin rates:

  * CPT 77387 (IGRT): $28.14
  * CPT 77402 (Level 1): $56.36
  * CPT 77407 (Level 2): $212.86
  * CPT 77412 (Level 3): $304.86

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Wisconsin Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Adjust bracketed fields before sending.

West Virginia

West Virginia DHHR - Commissioner

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Christy Donohue, Commissioner
West Virginia DHHR
350 Capitol Street, Room 251
Charleston, WV 25301-3706
christy.d.donohue@wv.gov

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in West Virginia to express grave concern regarding the current West Virginia Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for West Virginia beneficiaries.

Current West Virginia rates:

  * CPT 77387 (IGRT): $25.38
  * CPT 77402 (Level 1): $52.46
  * CPT 77407 (Level 2): $197.64
  * CPT 77412 (Level 3): $282.55

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of West Virginia Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Contact: [email protected].

Wyoming

Wyoming DOH - Medicaid Director

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Jesse Springer, Medicaid Director
Wyoming Department of Health
6101 Yellowstone Road, Suite 210
Cheyenne, WY 82009

Dear Medicaid Director:

I am writing to you in my capacity as [title / organization] with clients in Wyoming to express grave concern regarding the current Wyoming Medicaid reimbursement rates for essential radiation oncology services. These rates are unsustainable and place access to care at serious risk for Wyoming beneficiaries.

Current Wyoming rates:

  * CPT 77387 (IGRT): $32.83 (eff. 1/1/2026)
  * CPT 77402 (Level 1): $80.88 (eff. 1/1/2017)
  * CPT 77407 (Level 2): $285.41 (eff. 4/28/2026)
  * CPT 77412 (Level 3): $351.77 (eff. 4/28/2026)

CPT 77402 carries an effective date of 1/1/2017 - set nearly a decade before the 2026 code restructuring.

These rates do not cover the actual costs of delivering radiation therapy, which requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and clinical staff.

National Medicare benchmarks (effective January 1, 2026):

  * CPT 77387 (professional component): ~$36.74 (PFS non-facility)
  * CPT 77402 (Level 1): ~$79.49 (PFS) to $104.24 (HOPPS)
  * CPT 77407 (Level 2): ~$317.64 (PFS) to $394.05 (HOPPS)
  * CPT 77412 (Level 3): ~$391.46 (PFS) to $564.51 (HOPPS)

Approximately 60% of cancer patients receive radiation therapy. Inadequate reimbursement threatens provider participation and reduces access.

We respectfully request immediate review and alignment of Wyoming Medicaid rates for CPT codes 77387, 77402, 77407, and 77412 with Medicare benchmarks.

Sincerely,

[Your Name]
[Title / Organization]
[Contact Information]

Key: 77402 effective date of 1/1/2017 predates the 2026 restructuring by nearly a decade.

Ongoing Updates

Jump to: Training ↓

Developments as They Emerge

Sep 2026

Comprehensive 40+ State Rate Comparison Published

Ron completed a detailed, state-by-state Medicaid vs. Medicare comparison covering 40+ states and DC. The analysis sources each rate from the state’s official fee schedule portal and pairs it against locality-adjusted Medicare benchmarks. Findings include Medicaid-as-a-percentage-of-Medicare ratios ranging from 8% to over 800%, complexity inversions in at least seven states, and rates predating the CY2026 restructuring by years or decades.

Sep 2026

Connecticut Enacts Major Rate Increases Effective 7/1/2026

Connecticut confirmed substantial mid-year corrections: 77407 increased from $77.15 to $250.57 (+225%) and 77412 from $90.87 to $358.52 (+295%). The 77387 technical component was dropped from the schedule, mirroring Medicare’s CY2026 bundling policy.

Sep 2026

New Jersey Proposes Significant Rate Increases (Pending CMS Approval)

NJ’s August 2026 proposed fee schedule shows increases: 77402 from $21 to $42.62, 77407 from $21 to $160.79, and 77412 from $41 to $230.08. All three delivery codes now land at approximately 44.8% of the Newark Medicare benchmark. These remain proposed pending CMS approval.

Sep 2026

North Dakota Confirmed as Model State

North Dakota maintains rates at approximately 112% of Medicare across all four codes, reflecting a coherent annual update process tied to current Medicare RVUs with a 2% inflationary increase.

Sep 2026

Missouri Delivery Codes Confirmed “Noncovered” Since 1992

Missouri’s MO HealthNet fee schedule shows 77402, 77407, and 77412 as “Noncovered” with a rate effective date of 1/1/1992. By contrast, 77387 is properly covered effective 1/1/2026.

May 2026

Formal Letters Submitted to 35 State Medicaid Agencies

Ron submitted formal outreach letters to Medicaid agency leadership in 35 states documenting rate disparities and requesting immediate fee schedule review. Letters are available in the advocacy section above.

May 2026

Oregon Confirms Missing Codes Now Payable — Retroactive to 1/1/26

Oregon Health Authority confirmed that CPT codes 77402 and 77407 were unintentionally omitted. Rates of $64.83 (77402) and $258.88 (77407) are now payable retroactive to January 1, 2026.

May 2026

South Dakota Commended — Rates at or Above Medicare

Ron submitted a formal commendation letter recognizing South Dakota’s rates as meeting or exceeding Medicare benchmarks across all four codes.

Apr 2026

California: $0 Reimbursement for IGRT Confirmed

Medi-Cal confirmed as reimbursing $0 for CPT code 77387. Representatives indicated correction may not occur until 2027.

Jan 2026

2026 Procedure Code Transition Takes Effect

Radiation oncology treatment delivery codes consolidated under 77402, 77407, and 77412; image guidance consolidated under 77387. New definitions required payers to rebuild fee schedules — a transition many have not completed.

Education

Radiation Oncology Coding & Billing Training

RCCS Education

Radiation Oncology Coding & Billing Essentials

Major changes to radiation oncology coding and payment policies took effect January 1, 2026. RCCS offers live virtual seminars focused on correct coding for external beam procedures — 2D, electron, 3D, and IMRT — with clinically relevant examples, payer guidance, compliance review, and NCCI edit analysis. Each participant receives a copy of the 2026 Navigator® for Radiation Oncology (digital eNav®).

View Schedule →

RCCS provides oncology coding, compliance consulting, and revenue cycle management services nationwide. This resource is maintained by RCCS in support of Ron DiGiaimo’s ongoing advocacy on radiation oncology reimbursement.

About RCCS →

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