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A radiation oncologist in a rural freestanding center opens the 2026 payment summary.
CMS said the cut would be 1%. The actual number on the screen is 22%.

That gap is not a rounding error. It is a structural failure with real consequences for cancer access.

According to Newswise, citing an ASTRO statement submitted to CMS on September 14, 2026, more than two-thirds of radiation oncologists responding to an ASTRO survey reported payment declines of 10% or more following coding and payment changes implemented January 1. Many reported cuts of 20% to 30%. CMS had projected an overall reduction of just 1%.

That is not a forecast miss. That is a policy credibility problem.

I call this the Radiation Oncology Payment Gap Framework. Here is how to read it.

🔹 LAYER 1: The Projection vs. Reality Divide
CMS modeled aggregate impact across all settings. Freestanding and rural centers operate on far thinner margins than hospital outpatient departments. An aggregate 1% cut becomes a 20% to 30% cut when the mix of services skews toward lower-margin delivery settings.

🔹 LAYER 2: The Access Cliff
According to Newswise, more than 50 million Americans already live in counties without a radiation oncology practice. Rural and freestanding centers are the practices most likely to disappear when reimbursement math breaks. This is not theoretical. Every practice that closes is a county that loses access.

🔹 LAYER 3: The 2027 Pressure Points
ASTRO formally submitted comments to CMS on the proposed 2027 Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System. ASTRO is specifically urging CMS to correct a hospital payment assignment that continues to undervalue a commonly delivered service, with disproportionate impact on independent freestanding centers.

🔹 LAYER 4: The Structural Mismatch
The proposed 2027 rules include continued use of hospital data to inform freestanding payments. The problem is that hospital cost structures do not reflect freestanding reality. Using the wrong data source produces the wrong payment baseline every single cycle.

How to apply this today.

If you lead a freestanding radiation oncology practice or imaging center, audit your 2026 actual revenue against the January 1 projections line by line. If your gap is above 10%, document it and submit comments through ASTRO or directly to CMS. CMS does read formal comment submissions. They may not fix it fast, but the record matters for 2028 rulemaking.

The broader lesson here is simple.

Aggregate policy math does not protect individual practices. The providers most likely to close are the ones serving the patients least able to travel to an alternative site. When 50 million Americans already lack access to radiation oncology in their county, we cannot afford payment policy that treats access erosion as an acceptable rounding error.

Save this if you are planning your 2027 budget or commenting on the proposed MPFS rules. Your documented experience is the data CMS needs.

👉 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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