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Most radiation oncology programs missed the most expensive coding change of the decade.
They are still reading the 2026 Medicare fee schedule. The real threat lives in commercial payer contracts that have not caught up.
According to ECG Management Consultants, the AMA and CMS implemented the most significant overhaul of radiation oncology treatment delivery and image guidance coding in over a decade, effective January 1, 2026. These changes affect how EBRT, IMRT, and IGRT services are reported and reimbursed across all plans.
That last part matters. Across all plans. Not just Medicare.
🔍 Here is what actually changed:
🔹 EBRT delivery codes were restructured into three complexity tiers: 77402, 77407, and 77412. The old structure was based on technical criteria like number of ports. The new structure is based on delivery complexity regardless of technique.
🔹 IMRT delivery codes 77385 and 77386 were deleted. IMRT is no longer a distinct code. Those services now roll into the 77402 to 77412 tiers based on complexity.
🔹 The technical component of IGRT was bundled directly into the delivery codes. What was previously billed separately is now captured within a single line item.
This is where the revenue risk sits.
Commercial payers priced their fee schedules around the old code structure. If your contracts reference deleted codes, pay on percentage-of-charge models with outdated baselines, or include lesser-of provisions tied to old benchmark rates, your reimbursement just dropped without anyone sending you a notice.
📋 The 2026 Radiation Revenue Protection Checklist:
1. Pull every commercial payer contract that covers radiation services and identify how delivery and image guidance codes are referenced.
2. Flag any agreement that still references 77385 or 77386. Those codes no longer exist.
3. Audit percentage-of-charge contracts for updated charge masters that reflect the new bundled structure.
4. Test lesser-of provisions against current Medicare rates for 77402, 77407, and 77412.
5. Submit formal requests to payers to reprice services previously billed across multiple line items, now collapsed into single codes.
6. Document every request and response. Revenue neutrality has to be requested. It will not be granted automatically.
Save this checklist. Forward it to your revenue cycle director and your managed care contracting team today.
The practical application: a freestanding radiation oncology group that previously billed IMRT delivery under 77386 plus a separate IGRT line now has both rolled into 77407 or 77412. If the payer fee schedule still pays a flat rate based on the old 77386 rate without the image guidance add-on, that group is getting underpaid on every IMRT fraction it delivers.
No audit letter. No denial. Just quiet revenue erosion, fraction by fraction.
The lesson from this overhaul is not about CPT codes. It is about the gap between what CMS changes and what commercial payers actually implement without being pushed. That gap is where radiation oncology practices bleed money.
👉 Follow Jonathan Govette, CEO of Oatmeal Health, for daily healthcare insights on LinkedIn. Deeper dives in The Oatmeal Bite on Substack: https://news.oatmealhealth.com
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Author:
CEO/Co-Founder @ Oatmeal Health | AI Lung Cancer Screening | Almost Became a Doctor | Engineer | Follow to Share What I’ve Learned Along the Way
I help patients get the care they need earlier, preventing late-stage cancer.
That’s been the throughline across three companies and almost 20 years in healthcare. At ReferralMD, we fixed broken referral networks so patients didn’t fall through the cracks. At Oatmeal Health, it’s lung cancer: building the diagnostic and screening infrastructure so the 85% of cases caught too late get caught early instead.
Today as CEO of Oatmeal Health, I lead a team embedding AI into radiology workflows to turn routine lung CT scans into reimbursable cancer risk assessments. We partner with FQHCs to reach underserved communities, and with health systems and payers to make early detection economically sustainable. Think HeartFlow or Cleerly, but for lungs.
Between companies, I advised at Techstars and Plug and Play, mentoring founders building in digital health. That experience shaped how I think about what separates companies that ship from companies that stall: distribution, reimbursement, and clinical trust, not just technology.
I’m a CancerX alumnus, a 3x healthcare founder, and someone who believes the biggest problems in cancer aren’t scientific. They’re operational.
We’re hiring mission-driven builders at Oatmeal Health. If you want to work on something that matters, reach out.
When I’m not working, I’m traveling, mentoring, and keeping up with one very energetic husky. 🐾
Substack – The Oatmeal Bite:
Millions of patients get less care because of who they are, where they live, or how they look. I’m fighting to change that. CEO @OatmealHealth, a startup built for the underserved. The Oatmeal Bite: intel for clinicians, investors, and advocates.
Jonathan Govette
CEO of Oatmeal Health
Substack:
https://oatmealhealthjonathangovette.substack.com/
