
ACRO Issues Comments to CMS on Proposed Rules
As noted in the letters, "ACRO’s comments seek to ensure ongoing access to high-quality, state-of-the-art radiation oncology services."
ACRO has submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2026 Physician Fee Schedule (CMS-1832-P), as well as the CY 2026 Hospital Outpatient Prospective Payment System Proposed Rule (CMS-1834-P).
The first letter (CMS-1832-P) offers comments and recommendations on the following issues:
- Appropriate APC Placement for Treatment Delivery Codes (77402, 77407, 77412)
- Use of OPPS data to set PFS rates
- Updates to the Indirect Practice Expense (PE) Methodology
- Removal of 77427 from the Telehealth List
- Undervaluation of conversion factor due to G2211 Assumption
- Efficiency Adjustment
- Valuation of Imaging Guidance for Proton Beam Treatment Delivery (CPT codes 77520, 77522, 77523, and 77525)
The second letter (CMS-1834-P) offers comments on:
- Appropriate APC Placement for Treatment Delivery Codes (77402, 77407, 77412)
- BgRT
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