The presidents of ASTRO and ACRO provide focused analysis of CMS's 2026 proposed rules and their specific implications for radiation oncology practice. This executive briefing examines key policy changes without background context, concentrating on immediate implementation concerns and the September 12 comment period.

Key Topics Covered:

• Critical APC "crosswalk" methodology issues affecting new treatment delivery codes
• CMS's new "efficiency adjustment" reducing procedural service payments by 2.5%
• Transition from survey-based valuations to hospital cost data methodology
• Image guidance and port film bundling into treatment delivery codes
• Surface radiation therapy coding updates and valuation changes
• RUC committee dynamics and specialty representation challenges
• Strategic considerations for the comment period ending September 12, 2025

Technical Analysis: Dr. Sameer Keole (ASTRO President) and Dr. Brian Lally (ACRO President) and Drs Paravati and Rewari explain how CMS may have assigned new radiation therapy codes to incorrect ambulatory payment classifications. The analysis suggests CMS deleted separate IMRT codes but may not have recognized that IMRT services are now bundled into new level 2 and level 3 treatment codes, potentially resulting in significant undervaluation.

Policy Context: The discussion examines how radiation oncology's 21% decline in relative value over 20 years, combined with these proposed changes, affects practice sustainability. Freestanding centers face particular challenges with a 32% reimbursement reduction since 2015.

About Our Guests: Dr. Sameer Keole serves as President of ASTRO and practices radiation oncology in Arizona. Dr. Brian Lally is President of ACRO and practices at an academic center in South Carolina. Both provide extensive expertise in healthcare policy and specialty society leadership.

This focused analysis provides healthcare leaders with essential technical information for participating in the rulemaking process.

Note: This is a condensed version of our full Episode 18 analysis, focusing specifically on radiation oncology implications.

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Episode Tags: Medicare physician fee schedule, HOPPS, radiation oncology, ASTRO, ACRO, APC crosswalk, efficiency adjustment, CMS proposed rule, treatment delivery codes, comment period, healthcare policy analysis, specialty medicine, supercut