Industry Advocacy Resource

Radiation Oncology Fee Schedule Changes

Ron DiGiaimo, MBA FACHE — Chairman of R3 and CEO of RC Billing — has been leading ongoing advocacy around reimbursement conditions threatening radiation oncology access across the country. This page centralizes his research, state-level findings, and advocacy materials, and is maintained and supported by RCCS.

Led by Ron DiGiaimo, MBA FACHE • Supported by RCCS

Updated: May 2026 Codes: 77387 • 77402 • 77407 • 77412 15 States Documented

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✓ 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. Oregon acknowledged Ron’s concerns about rate adequacy and will note them for the next rate-change review cycle.

Ron’s Perspective

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.

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

What We Know — and What Is Still Evolving

Confirmed

• January 1, 2026 coding transition consolidated treatment delivery into 77402, 77407, and 77412; image guidance into 77387
• Code definitions changed materially — payers were required to rebuild fee schedules, update billing systems, and retest claims processing
• Multiple Medicaid programs have not completed this update; several states retain rates set years before the new code structure
• California Medi-Cal reimburses $0 for 77387; New Mexico also $0; Indiana lists $0 for 77387 and does not list 77412
• Hawaii does not list 77387 at all; New Jersey reimburses only $21–$41 for technical components; Oregon confirmed 77402 and 77407 were missing entirely
• Ron has submitted formal outreach letters to Medicaid agencies in 15 states

Still Developing

• California indicating correction timeline extending to 2027
• TX: 77402, 77407, 77412 listed as Not Payable for physicians; 77387 categorized by type of service
• MA: all four codes “Individual Consideration” — no predictable payment floor
• NJ: rates listed “By Report” for 77387; technical-only payments of $21–$41 for delivery codes
• IN: 77412 not listed; 77387 at $0; 77407 same rate as 77402
• NH: 77412 ($48.17) lower than 77402 ($63.32) — inverted rate structure suggesting incomplete update
• NY and SC: Level 3 rate lower than Level 2 rate — similar inversion issue
• Oregon: rates now payable but remain below Medicare benchmarks

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

State-Level Data

Medicaid vs. Medicare: Rate Comparison by State

The table below documents current reimbursement rates for the primary radiation oncology codes under state Medicaid programs, compared against Medicare benchmarks effective January 1, 2026.

State / Program	77387 (IGRT)	77402 (Level 1)	77407 (Level 2)	77412 (Level 3)
Alabama	$24.07	$50.18	$189.42	$272.53
California (Medi-Cal)	$0	$42.40	$38.77	$43.20
Florida	$12.19 (PC)	--	$149.00	$158.42
Hawaii	Not listed	$58.71	$68.94	$76.99
Indiana	$0	$101.97	$101.97	Not listed
Massachusetts	All codes: “Individual Consideration” — no fixed rate
Michigan	$23.22 (Prof)	Delivery code rates not confirmed in outreach letter
New Hampshire	--	$63.32	$74.72	$48.17
New Jersey	By Report	$21 (TC only)	$21 (TC only)	$41 (TC only)
New Mexico	$0	--	$92.24	$102.63
New York	$71.10 Global / $10.08 PC	$98.20	$166.27	$151.45
Oregon ✓	$29.52	$64.83 ↑	$258.88 ↑	$319.07
South Carolina	$82.57 / $24.77 PC	$98.04	$154.02	$149.12
Texas	$16.31 (PC) / $44.11 (TC)	77402, 77407, 77412 listed as Not Payable for physicians
Virginia	--	--	$219.55	$208.42
Washington	$21.12 (PFS) / Bundled TC	$50.09	$188.97	$270.46
Medicare PFS (non-facility)	$36.74 (PC)	$79.49	$317.64	$391.46
Medicare HOPPS	--	$104.24	$394.05	$564.51

Oregon (green) reflects advocacy win: codes 77402 and 77407 added to fee schedule, payable retroactive to 1/1/26. Virginia rates carry effective dates of 2014–9999. NH, NY, and SC show inverted rate structures (higher-complexity code pays less than lower-complexity). Commercial payers often reimburse 77387 at $100–$130 (professional component).

Impact Assessment

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

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. Below are ways to stay current and participate.

Follow Ron on LinkedIn

Ron is posting ongoing developments, state-specific findings, and calls to action as this issue evolves. Following him is the fastest way to stay current between updates to this page.

Follow on LinkedIn →

Watch This Page

This resource is updated as new state data, agency responses, and advocacy materials become available. Bookmark it as the centralized reference for this campaign and share the URL with colleagues and organizations that 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 15 states are available below, alphabetized by state.

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.

ron@r3sourcehealth.com →

Advocacy Letters

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. Alphabetized by state.

AL FL HI IN MA MI NH NJ NM NY OR ✓ SC TX VA WA

Alabama

Alabama Medicaid Agency — Commissioner

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Alabama Medicaid Agency Commissioner [Verify current commissioner name and contact information before submitting] Dear Commissioner: 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 rates are unsustainable and place timely access to care at serious risk for Alabama Medicaid beneficiaries. Alabama Medicaid currently provides the following rates: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $24.07 • CPT 77402 (Radiation Treatment Delivery, Level 1): $50.18 • CPT 77407 (Radiation Treatment Delivery, Level 2): $189.42 • CPT 77412 (Radiation Treatment Delivery, Level 3): $272.53 These rates are catastrophically low and 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 and may be forced to discontinue services for Alabama Medicaid patients in many communities. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026, under the revised 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 Medicaid's rates are materially lower than Medicare's, creating an untenable disparity. These national rates, at minimum, allow practices to maintain operations and invest in the modern technology required for accurate, image-guided treatment. 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. 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. 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. Thank you for your immediate attention to this patient-access issue. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending. Verify the current Alabama Medicaid commissioner before submitting.

Florida

Florida Agency for Health Care Administration — 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 Deputy Secretary Meyer: 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 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 Florida beneficiaries who require this life-saving treatment for cancer. Specifically, Florida currently provides reimbursement at the following rates: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $12.19 (professional component) • CPT 77407 (Radiation Treatment Delivery, Level 2): $149.00 • CPT 77412 (Radiation Treatment Delivery, Level 3): $158.42 These rates are materially inadequate and 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 or complete discontinuation of services — directly jeopardizing patient outcomes in a vulnerable population that already faces barriers to care. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026, under the revised coding structure — are substantially higher and reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) Florida'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 the 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 Florida 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 Florida Medicaid payment rates for CPT codes 77387, 77407, and 77412 with national Medicare benchmarks — or a reasonable cost-based equivalent — to ensure continued access to these critical services. Thank you for your immediate attention to this patient-access issue. We look forward to your response and to collaborative action to protect Florida beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending.

Hawaii

Hawaii Department of Human Services — 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 Med-QUEST Division Administrator: 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 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 Hawaii beneficiaries who require this life-saving treatment for cancer. Specifically, Hawaii currently does not list CPT code 77387 on its fee schedule. The rates for the revised radiation treatment delivery codes are as follows: • CPT 77387 (IGRT – Guidance for Radiation Treatment): Not listed • CPT 77402 (Radiation Treatment Delivery, Level 1): $58.71 • CPT 77407 (Radiation Treatment Delivery, Level 2): $68.94 • CPT 77412 (Radiation Treatment Delivery, Level 3): $76.99 These rates do not come close to covering the actual costs of delivering safe 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 Hawaii patients in many communities. This directly jeopardizes patient outcomes in a vulnerable population that already faces barriers to care. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — are substantially higher and reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) Hawaii's rates are materially lower than Medicare's — and 77387 is not listed at all — creating an untenable disparity. These national rates, at minimum, 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 Hawaii Medicaid networks, reduces geographic access, and risks increased downstream costs to the state from unmanaged disease progression. We respectfully request that your team immediately review and align Hawaii 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 look forward to your response and to collaborative action to protect Hawaii beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending.

Indiana

Indiana Family and Social Services Administration — 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 Director of Medicaid: 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 who require this life-saving treatment for cancer if these facilities are forced to halt services. Specifically, Indiana currently provides $0 reimbursement for CPT code 77387 (Guidance for localization of target volume for delivery of radiation treatment), and CPT code 77412 does not appear to be listed in the fee schedule at all. The current rates are as follows: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $0 • CPT 77402 (Radiation Treatment Delivery, Level 1): $101.97 • CPT 77407 (Radiation Treatment Delivery, Level 2): $101.97 (same rate as Level 1 — does not reflect increased complexity) • CPT 77412 (Radiation Treatment Delivery, Level 3): Not listed These rates are catastrophically low or absent from the fee schedule and do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. The absence of 77412 from the fee schedule is particularly damaging to access. 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 Indiana patients in many communities. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — are substantially higher and reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) Indiana's rates are materially lower than Medicare's — or absent entirely — creating an untenable disparity. These national rates, at minimum, 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 Indiana Medicaid networks, reduces geographic access, 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 Indiana 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. We look forward to your response and to collaborative action to protect Indiana beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending. Explicitly raising the absence of 77412 and the identical rates for 77402/77407 strengthens the letter.

Massachusetts

MassHealth — Medicaid Director

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[MassHealth Medicaid Director] MassHealth [Verify current director name and contact information before submitting] Dear MassHealth Director: I am writing to you in my capacity as [title / organization] with clients in Massachusetts to express grave concern regarding the current MassHealth payment structure for essential radiation oncology treatment delivery and guidance services. Specifically, Massachusetts Medicaid currently lists CPT codes 77387, 77402, 77407, and 77412 as "Individual Consideration," meaning there is no fixed payment rate for any of these codes. Without active provider engagement and advance approval, this structure creates a meaningful risk of non-payment for covered services that are essential to cancer care for Massachusetts Medicaid beneficiaries. The codes at issue are: • CPT 77387 (IGRT – Guidance for Radiation Treatment): Individual Consideration — no fixed rate • CPT 77402 (Radiation Treatment Delivery, Level 1): Individual Consideration — no fixed rate • CPT 77407 (Radiation Treatment Delivery, Level 2): Individual Consideration — no fixed rate • CPT 77412 (Radiation Treatment Delivery, Level 3): Individual Consideration — no fixed rate This creates a fundamentally unpredictable payment environment for providers. Without a defined payment floor, radiation oncology centers cannot project revenue, sustain operations, or make capital investments in the equipment and staffing required to deliver these services safely and effectively. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — provide clear, defined rates that reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) 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. Unpredictable reimbursement threatens provider participation in MassHealth networks, reduces geographic access (particularly in underserved areas), and risks increased downstream costs to the state from unmanaged disease progression. We respectfully request that MassHealth establish defined payment rates for CPT codes 77387, 77402, 77407, and 77412 aligned with national Medicare benchmarks — or a reasonable cost-based equivalent — to ensure continued access to these critical services. Thank you for your attention to this patient-access issue. We look forward to your response and to collaborative action to protect Massachusetts Medicaid beneficiaries. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Verify the current MassHealth director name and contact before submitting. The "Individual Consideration" structure is the primary concern to emphasize.

Michigan

Michigan Department of Health and Human Services — 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 who require this life-saving treatment for cancer if these facilities are forced to halt services. Michigan currently provides the following documented rate for radiation guidance: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $23.22 (professional component) Rates for CPT codes 77402, 77407, and 77412 (Radiation Treatment Delivery, Levels 1–3) require verification against the current Michigan Medicaid fee schedule and are of equal concern given the pattern of inadequate reimbursement documented across other states following the January 1, 2026 coding transition. 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 inadequate reimbursement levels, practices cannot absorb ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Michigan 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) • 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) 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 Michigan Medicaid networks, reduces geographic access, 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 Michigan 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]

Adjust bracketed fields before sending. Confirm current Michigan Medicaid delivery code rates before submitting.

New Hampshire

New Hampshire Department of Health & Human Services — Medicaid Director

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Henry Lipman, Medicaid Director New Hampshire Department of Health & Human Services 129 Pleasant Street Concord, New Hampshire 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 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 New Hampshire beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services. New Hampshire currently provides the following rates for the revised radiation treatment delivery codes: • CPT 77402 (Radiation Treatment Delivery, Level 1): $63.32 • CPT 77407 (Radiation Treatment Delivery, Level 2): $74.72 • CPT 77412 (Radiation Treatment Delivery, Level 3): $48.17 These rates are catastrophically low. Notably, the Level 3 rate ($48.17) — representing the most complex and resource-intensive treatment — is lower than the Level 1 rate ($63.32). This inverted rate structure strongly suggests the fee schedule has not been properly updated to reflect the 2026 code definitions and resource requirements. 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 New Hampshire 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 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) New Hampshire's rates are materially lower than Medicare's, and the inverted rate structure indicates these rates were not updated to align with the 2026 code transition. 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 New Hampshire Medicaid networks and reduces geographic access to care. We respectfully request that your team immediately review and align New Hampshire 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. We look forward to your response. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending. NH's inverted rate structure (Level 3 pays less than Level 1) is a strong additional argument — highlight it prominently.

New Jersey

NJ Division of Medical Assistance & Health Services — 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 Assistant Commissioner: 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 payment 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 New Jersey beneficiaries. Specifically, New Jersey currently lists CPT code 77387 as reimbursable "By Report" only, with no defined payment rate. The rates for the revised radiation treatment delivery codes are as follows: • CPT 77387 (IGRT – Guidance for Radiation Treatment): By Report — no defined rate • CPT 77402 (Radiation Treatment Delivery, Level 1): $21 (Technical Component only) • CPT 77407 (Radiation Treatment Delivery, Level 2): $21 (Technical Component only) • CPT 77412 (Radiation Treatment Delivery, Level 3): $41 (Technical Component only) These rates are catastrophically low and do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. The absence of defined professional component rates means physicians cannot reliably bill for their services. 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 New Jersey patients. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — are substantially higher and reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) New Jersey's rates are materially lower than Medicare's — or undefined in the case of 77387 — creating an untenable disparity. 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 New Jersey Medicaid networks and reduces geographic access to care. We respectfully request that your team immediately review and align New Jersey 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 look forward to your response and to collaborative action to protect access to radiation oncology care for New Jersey beneficiaries. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending.

New Mexico

New Mexico Health Care Authority — Medicaid Director

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Alanna Dancis, Medicaid Director New Mexico Health Care Authority alanna.dancis@hca.nm.gov Dear Director Dancis: 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 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 New Mexico patients who require this life-saving treatment for cancer. Specifically, New Mexico Medicaid currently provides the following rates: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $0 • CPT 77407 (Radiation Treatment Delivery, Level 2): $92.24 • CPT 77412 (Radiation Treatment Delivery, Level 3): $102.63 These rates are catastrophically low and 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 New Mexico patients in many communities. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026, under the revised coding structure — are substantially higher and reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) New Mexico's rates are materially lower than Medicare's — or zero, in the case of 77387 — creating an untenable disparity. 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 New Mexico Medicaid networks, reduces geographic access, and increases downstream costs to the state from unmanaged disease progression. We respectfully request that your team immediately review and align New Mexico Medicaid payment rates for CPT codes 77387, 77407, and 77412 with national Medicare benchmarks — or a reasonable cost-based equivalent — to ensure continued access to these critical services. Thank you for your immediate attention to this patient-access issue. We look forward to your response and to collaborative action to protect New Mexico beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

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New York

New York Department of Health — Medicaid Director / Deputy Commissioner

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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 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 New York beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services. New York currently provides the following rates: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $71.10 Non-facility & Facility Global / $10.08 Professional Component • CPT 77402 (Radiation Treatment Delivery, Level 1): $98.20 Non-facility & Facility Global • CPT 77407 (Radiation Treatment Delivery, Level 2): $166.27 Non-facility & Facility Global • CPT 77412 (Radiation Treatment Delivery, Level 3): $151.45 Non-facility & Facility Global These rates do not come close to covering the actual costs of delivering radiation therapy. Of particular concern, the Level 3 delivery rate ($151.45) is lower than the Level 2 rate ($166.27), which does not reflect the substantially greater resources required for complex treatment delivery. At these reimbursement levels, practices cannot absorb ongoing operational expenses — directly jeopardizing patient outcomes. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) New York's rates are materially lower than Medicare's, creating an untenable disparity. 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 New York Medicaid networks, reduces geographic access, and increases downstream costs to the state from unmanaged disease progression. We respectfully request that your team immediately review and align New York 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. We look forward to your response and to collaborative action to protect New York beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending. NY's inverted rate structure (Level 3 lower than Level 2) is a useful additional argument for rate correction.

Oregon ✓ Win

Oregon Health Authority — Medicaid Director

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Emma Sandoe, Medicaid Director State of Oregon, 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 ongoing concern regarding the current Oregon Medicaid reimbursement rates for essential radiation oncology treatment delivery and guidance services. Note: Oregon Health Authority has confirmed that CPT codes 77402 and 77407 were unintentionally omitted from the fee schedule. These codes are now payable at $64.83 (77402) and $258.88 (77407), retroactive to January 1, 2026. We appreciate this correction and acknowledge it as a meaningful step forward. This letter continues to advocate for rate adequacy across all four codes. The current rates for radiation oncology services are as follows: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $29.52 (Facility and Non-facility) • CPT 77402 (Radiation Treatment Delivery, Level 1): $64.83 (confirmed payable as of May 2026) • CPT 77407 (Radiation Treatment Delivery, Level 2): $258.88 (confirmed payable as of May 2026) • CPT 77412 (Radiation Treatment Delivery, Level 3): $319.07 CPT codes 77402 and 77407 represent the majority of radiation oncology treatment volume. While their addition to the fee schedule is welcome, the rates remain substantially below Medicare benchmarks. 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 face ongoing pressure that over time leads to reduced capacity or discontinuation of services for Oregon Health Plan patients. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) Oregon's rates remain meaningfully below Medicare benchmarks, creating a persistent disparity. 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 Oregon Health Plan networks, reduces geographic access (particularly in underserved areas), and risks increased downstream costs to the state from unmanaged disease progression. We respectfully request that your team continue to work toward aligning Oregon 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. We look forward to your continued engagement to protect Oregon Health Plan beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Oregon confirmed 77402 and 77407 are now payable retroactive to 1/1/26 — this updated letter acknowledges that win while continuing to advocate for rate adequacy. Adjust bracketed fields before sending.

South Carolina

South Carolina Healthy Connections Medicaid — Medicaid Director

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Eunice Medina, Medicaid Director South Carolina Healthy Connections Medicaid State of SC, Department of Health & Human Services 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 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 South Carolina beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services. South Carolina currently provides the following rates: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $82.57 global / $24.77 Professional Component • CPT 77402 (Radiation Treatment Delivery, Level 1): $98.04 • CPT 77407 (Radiation Treatment Delivery, Level 2): $154.02 • CPT 77412 (Radiation Treatment Delivery, Level 3): $149.12 These rates are catastrophically low and do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Of note, the Level 3 delivery rate ($149.12) is lower than the Level 2 rate ($154.02), which does not reflect the substantially greater resources required for complex treatment delivery. 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. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — 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) South Carolina's rates are materially lower than Medicare's, creating an untenable disparity. 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 South Carolina Medicaid networks and places access at risk, particularly in underserved communities. We respectfully request that your team immediately review and align South Carolina 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 look forward to your response and to collaborative action to protect South Carolina beneficiaries' access to radiation oncology care. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending. SC's inverted rate structure (Level 3 lower than Level 2) is a useful additional argument.

Texas

Texas Health and Human Services Commission — Medicaid Director

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[Texas Medicaid Director] Texas Health and Human Services Commission [Verify current director name and contact information 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 structure for essential radiation oncology treatment delivery and guidance services. These conditions are unsustainable and place timely access to care at serious risk for Texas Medicaid beneficiaries. Specifically, Texas Medicaid currently lists CPT codes 77402, 77407, and 77412 (Radiation Treatment Delivery, Levels 1–3) as Not Payable for physician services. Additionally, CPT code 77387 (IGRT) is categorized by type of service rather than by procedure code, creating cross-reference confusion for billing providers. The current rates, to the extent they can be confirmed, are: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $16.31 (Professional Component) / $44.11 (Technical Component) — categorized by type of service • CPT 77402 (Radiation Treatment Delivery, Level 1): Not Payable for physician services • CPT 77407 (Radiation Treatment Delivery, Level 2): Not Payable for physician services • CPT 77412 (Radiation Treatment Delivery, Level 3): Not Payable for physician services The practical effect of listing treatment delivery codes as not payable for physicians is a severe barrier to provider participation. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. Without defined reimbursement, practices cannot sustain operations for Texas Medicaid patients in many communities. This directly jeopardizes patient outcomes in a vulnerable population that already faces barriers to care. By comparison, national Medicare benchmarks for these same services — updated effective January 1, 2026 — are substantially higher and reflect the true resources involved: • CPT 77387 (professional component only): approximately $36.74 (Medicare PFS non-facility) • 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) 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 Texas Medicaid networks, reduces geographic access, 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 establish defined Texas Medicaid payment rates for CPT codes 77387, 77402, 77407, and 77412 aligned with national Medicare benchmarks — or a reasonable cost-based equivalent — to ensure continued access to these critical services. Thank you for your immediate attention to this patient-access issue. We look forward to your response and to collaborative action. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Verify the current Texas Medicaid director before submitting. The "Not Payable for physician services" designation for delivery codes is the primary concern to lead with.

Virginia

Virginia Department of Medical Assistance Services — 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 Re: Urgent Request to Update and Correct Medicaid Payment Rates for Radiation Oncology Services – CPT Codes 77407 and 77412 Dear Director Ford: 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 treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Virginia beneficiaries who require this life-saving treatment for cancer. Virginia Medicaid currently provides the following rates for the revised treatment delivery codes: • CPT 77407 (Radiation Treatment Delivery, Level 2): $219.55 (effective dates 2014–9999) • CPT 77412 (Radiation Treatment Delivery, Level 3): $208.42 (effective dates 2014–9999) These rates do not reflect the 2026 description of service, which differs materially from the historical code descriptions applied when these codes were previously active. The effective date range (2014–9999) indicates these rates have not been updated to align with the January 1, 2026 procedure code revision. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these levels, practices cannot absorb ongoing operational expenses — leading to reduced capacity, delayed treatments, or complete discontinuation of services for Virginia patients. Medicare benchmarks for these same services — updated effective January 1, 2026 — are substantially higher and reflect the true resources involved: • 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) Virginia's rates are significantly lower than Medicare's, creating an untenable disparity. The situation is urgent. Radiation therapy is a cornerstone of cancer care — approximately 60% of patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Virginia Medicaid networks, reduces geographic access, and increases downstream costs to the state from unmanaged disease progression. We respectfully request that your team immediately review and align Virginia Medicaid payment rates for CPT codes 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 meet to discuss this matter promptly. We look forward to your response and to collaborative action to protect Virginia Medicaid beneficiaries. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending. Virginia's 2014 effective date on current rates is a strong argument — raise it explicitly.

Washington

Washington 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 Re: Urgent Request to Update and Correct Medicaid Payment Rates for Radiation Oncology Services – CPT Codes 77387, 77402, 77407, and 77412 Dear Director Wilson: I am writing to you in my capacity as [title / organization] with clients in Washington State to express grave concern regarding the current Washington 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 Washington beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services. The current rates for the revised radiation treatment codes are as follows: • CPT 77387 (IGRT – Guidance for Radiation Treatment): $21.12 (PFS) / Bundled for Technical Component • CPT 77402 (Radiation Treatment Delivery, Level 1): $50.09 • CPT 77407 (Radiation Treatment Delivery, Level 2): $188.97 • CPT 77412 (Radiation Treatment Delivery, Level 3): $270.46 These rates are materially low and 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 Washington patients in many communities. This directly jeopardizes patient outcomes in a vulnerable population that already faces barriers to care. 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) • 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) Washington's rates are materially lower than Medicare's, creating an untenable disparity that does not allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment. The situation is urgent. Radiation therapy treats approximately 60% of cancer patients at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Washington Medicaid networks and reduces geographic access to this essential care. We respectfully request that your team review and align Washington 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. Sincerely, [Your Name] [Title / Organization] [Contact Information]

Adjust bracketed fields before sending.

Ongoing Updates

Developments as They Emerge

May 2026

National

Resource Center Expanded — Now Covering 15 States

Ron expands this centralized resource, supported by RCCS, adding Washington, Oregon, New York, Hawaii, South Carolina, New Hampshire, New Jersey, Michigan, and Indiana to the documented state list.

May 2026

Oregon ✓

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

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. Oregon acknowledged the rates remain low and will note Ron's concerns for the next rate-change review cycle.

May 2026

Washington

Formal Letter Submitted to WA State Health Care Authority

Ron submitted a formal letter to Director Trinity Wilson documenting rates of $21.12 (77387), $50.09 (77402), $188.97 (77407), and $270.46 (77412) against Medicare benchmarks, requesting immediate review.

May 2026

Multi-State

New Outreach Letters: HI, IN, MI, NH, NJ, NY, SC

Ron submitted formal outreach letters to Medicaid agency leadership in Hawaii, Indiana, Michigan, New Hampshire, New Jersey, New York, and South Carolina documenting rate disparities and requesting immediate fee schedule review.

Apr 2026

Multi-State

Initial Formal Outreach Letters Submitted

Ron submitted formal letters to Medicaid agency leadership in Florida, New Mexico, Virginia, and Alabama documenting rate disparities and requesting immediate fee schedule review.

Apr 2026

California

Medi-Cal: $0 Reimbursement for IGRT Confirmed

California Medi-Cal confirmed as reimbursing $0 for CPT code 77387. Medi-Cal representatives indicated correction may not occur until 2027 — a timeline Ron has flagged as untenable for affected practices.

Apr 2026

New Mexico

Zero Reimbursement for IGRT; Delivery Rates Far Below Medicare

New Mexico Medicaid lists $0 for 77387 and rates of $92.24 and $102.63 for 77407 and 77412, compared to Medicare benchmarks of $317–$394 and $391–$565.

Apr 2026

Texas

Delivery Codes Listed as Not Payable for Physicians

Texas Medicaid lists CPT codes 77402, 77407, and 77412 as not payable for physician services. IGRT (77387) is categorized by type of service rather than procedure code, creating billing confusion.

Apr 2026

Massachusetts

All Key Codes Listed as “Individual Consideration”

Massachusetts Medicaid has no fixed payment rates for 77387, 77402, 77407, or 77412. Without active provider engagement, the structure creates meaningful risk of non-payment.

Jan 2026

National

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 and update billing systems — a transition many have not completed.

Perspective

From the Desk of Ron DiGiaimo

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 • ron@r3sourcehealth.com • LinkedIn

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.

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