Pulse Check: Reminders and Alerts for Providers in 2026

With calendar year (CY) 2026 well underway, this time of year offers providers an opportunity to step back and conduct a pulse check on financial compliance issues. There were several coding changes for radiation oncology providers, and the first quarter of 2026 highlighted many issues and opportunities for providers to ensure they are doing their due diligence. Medical oncology providers did not see changes to coding per se, but there have been clarifications on a key service.

Radiation Oncology External Beam Treatment Delivery

Effective in 2026, there are 3 codes from the American Medical Association (AMA) for coding external beam radiation therapy (EBRT) and 1 code for image-guided radiation therapy (IGRT). All cancer centers, regardless of setting (eg, hospital-based or freestanding), will use the updated AMA codes. There are no longer differences between sites of service for reporting EBRT and IGRT. Additionally, all payers now require providers to use the revised coding convention effective January 1, 2026.

The close of Q1 2026 has identified many opportunities for providers and payers to check in, address mistakes, and take advantage of opportunities they missed during the busy start to the new year. The following are a few reminders and key takeaways for providers to consider as the year progresses.

Payers Not Ready for Radiation Oncology Coding Changes

Medicare Administrative Contractor (MAC) Palmetto GBA resolved the issue of denying claims for Current Procedural Terminology® (CPT®) code 77387: Guidance for localization of target volume for delivery of radiation treatment, includes intrafraction tracking, when performed. Palmetto GBA indicated that providers received claims denials for CPT code 77387 with modifiers 26 or TC for 2026 dates of service.¹ This was due to the code not being listed as a recognized code by the Centers for Medicare & Medicaid Services (CMS). Palmetto GBA indicated that it provided a mass adjustment, and providers did not need to do anything. As of March 6, 2026, Palmetto GBA indicated that the issue has been resolved.

UnitedHealthcare (UHC) changed course and updated its policy, Bundled Codes Policy, Professional, by removing 2 radiation oncology-based codes from bundling.² Prior to January 18, 2026, UHC listed CPT codes 77387 and 77439 as bundled, even if a modifier was appended. This removed the opportunity for physicians to be reimbursed for their work related to IGRT and for verifying the surface radiation therapy treatment field prior to treatment. On January 18, 2026, UHC updated the list of bundled codes, removing both 77387 and 77439.

Pulse Check

1. Providers under MAC Palmetto GBA should review their records to ensure they have appropriately tracked and allocated to providers internally and that there are no other outstanding issues.
2. Providers with beneficiaries for UHC should verify that there are no outstanding issues and ensure proper payment is received for services supported by these 2 codes.

Providers Challenged With Coding and Billing Radiation Oncology Changes

In review of documentation and claims data, many radiation oncology providers have not set up the revised radiation oncology treatment delivery codes within their electronic medical records (ie, ARIA® and MOSAIQ®) to route correctly into the Epic electronic health record.

Prior to 2026, CPT codes 77402, 77407, and 77412 for treatment delivery were only recognized in the hospital setting for hospital billing by CMS and private payers. Effective in 2026, these codes are now the only treatment-delivery codes available, regardless of setting. Additionally, CPT code 77387 for IGRT is the only available code and is only for physician billing—not hospital billing.

Pulse Check

1. Providers should check the routing of their codes when they export from charge capture within ARIA and MOSAIQ to Epic to ensure the codes are routed to hospital billing and physician billing correctly. Many cancer programs may still have routing issues and have not adjusted for CY 2026.

Radiation Oncology Providers Challenged With Chargemaster Pricing for Updated Codes

CPT codes 77402, 77407, and 77412 are not new codes; they were first introduced in January 1993. Since then, these codes have undergone revisions, most notably in 2015 when they were the only 3 codes maintained by the AMA for coding of treatment delivery.

At that time, CMS only recognized the codes in the hospital setting, and freestanding cancer centers had to use G-codes for the same services. Now that the G-codes have been deleted and codes 77402, 77407, and 77412 are available to everyone, many cancer centers have reverted to pre-2015 pricing. This has also happened for many payers, who, rather than establish a current rate, have reverted to previous rates. Therefore, providers are likely not being paid appropriately.

Pulse Check

1. Radiation oncology providers should complete a review of chargemaster and payer contracts to ensure pricing is appropriate to CY 2026 and account for the revisions to the definitions. The current codes do not differentiate between 3D and intensity-modulated radiation therapy treatments. Most providers only update their chargemaster when new codes are added, not when previously used codes are renewed and are now applicable.
2. Check on payer denial issues. Several providers are experiencing denials for services due to codes missing from payer fee schedules and/or payment systems. This results in delayed or denied payments, which may not be appropriate.

Medical Oncology Chemotherapy Education Visits

Patient education is provided in addition to oncology services, especially during chemotherapy administration. There has always been some uncertainty about whether this work could be billed separately. Some payer guidance has been unclear, and some providers have developed creative solutions to recoup costs for the resources they provide. The AMA provided clarification and guidance regarding when chemotherapy education may be separately reported.³

Reporting Separately

Chemotherapy education may be reported separately when the service is performed by a physician or other qualified health care professional (QHP), and documentation supports a reportable Evaluation and Management (E/M) service. Chemotherapy administration services do not have a global surgical package, so education related to the regimen may qualify for separate reporting when it meets E/M requirements.

Reporting Based on Provider Type

The appropriate billing for the chemotherapy education will depend on which provider performed the education:

• Physician or QHP: Report E/M service (CPT code 99202-99215) when documentation supports the level.
• Registered Nurse (RN): Report Principal Care Management (PCM) (CPT code 99426 or 99427) code when criteria are met.
• Shared visit (RN + physician/QHP): Report only physician/QHP time counts toward E/M level if reporting is based on time.

When selecting the E/M level based on time, the physician or QHP may include counseling regarding chemotherapy treatment, review of education materials and handouts, discussion of treatment expectations and adverse effects, symptom management education, and coordination of care for upcoming treatment. Do not include time spent on clerical or administrative tasks, time spent solely by nursing staff, or infusion administration activities.

Infusion Nurse Times: Understand Limitations

Nursing time associated with chemotherapy administration cannot be counted toward E/M time or PCM services. Typical infusion nursing activities include:

• Verifying medication orders and doses
• Establishing IV access
• Administering chemotherapy drugs
• Monitoring the patient during infusion
• Coordinating discharge.

For example, initial drug infusion (CPT code 96413) includes approximately 98 minutes of nursing time, which is already accounted for in the infusion service.

Same-Day Chemotherapy Administration

If chemotherapy administration occurs on the same date of service, an E/M service may still be reported when it is significant and separately identifiable. Key requirements include:

• Report the appropriate E/M code with modifier 25
• Documentation must show extensive counseling or education by the physician/ QHP
• The service must be distinct from infusion supervision.

A different diagnosis is not required for same-day E/M reporting.

Documentation Reminders

Compliant billing requires supporting documentation. This may vary based on the provider and the billable service to be supported. Some key components include:

• Identify who performed the education.
• Document the total physician/QHP time on the date of service.
• Describe the education provided and counseling performed.
• Note any discussion of adverse effects and symptom management.
• Clearly separate the education visit from infusion services.

Chemotherapy education encounters can be separately reported when a physician or QHP provides extensive counseling or care coordination, and documentation clearly supports a distinct E/M service.

Pulse Check

1. Review current processes for chemotherapy education to identify if there are opportunities for reporting or if changes are needed to ensure compliant reporting.

The beginning of each new calendar year brings a lot of new information on coding, billing, and reimbursement. Typically, quarters 2, 3, and 4 provide opportunities to assess the challenges, issues, errors, and need for process changes. Once things have settled down, this is when payers provide more clarification to address what they are experiencing, and for providers to assess their preparedness and determine whether payers are adhering to the new rules. With all the changes in CY 2026, there are many opportunities to learn, check in, and participate.

Teri Bedard, BA, RT (R)(T), CPC, is executive director of Client and Corporate Resources at Revenue Cycle Coding Strategies in Des Moines, Iowa.

References

1. RESOLVED: claim rejections for radiology treatment. Palmetto GBA. March 10, 2026. Accessed April 28, 2026. https://palmettogba.com/ jmb/did/jlbmzif9m9?cat=jmb-claims

2. UnitedHealthcare® commercial and individual exchange, reimbursement policy, CMS 1500, policy number 2026R0100B. Accessed April 28, 2026. https://www.uhcprovider.com/content/dam/ provider/docs/public/policies/comm-reimbursement/COMM-B-Bundle-Codes-Policy.pdf

3. CPT® coding support with CPT Assistant. American Medical Association. Updated April 18, 2025. Accessed April 28, 2026. https://www. ama-assn.org/practice-management/cpt/ cpt-coding-support-cpt-assistant