2026 Coding Updates – Q&A

1. Is the physics code billed per week or per 5 fractions?
   1. The CPT codebook currently states that this code is billable once per week.
   2. Please note that in order to bill this code, a license physicist will need to conduct weekly/monthly patient chart checks. Annual calibrations are not billable for services therefore without ongoing physics checks this code should not be used.

2. For new patients who need prior authorization from their insurance, are you guys (MedIQ) currently doing the authorization for the current or new codes?
   1. Yes and No. The MedIQ team is checking daily to see whether the new codes are added to the commercial/authorization sites. However, currently, they have not updated the information.
   2. Currently authorization requests are being obtained using the old CPT codes.
   3. For authorizations requests beginning January 1, the new codes will be used.

 

3. We are having a large number of denials for EM codes billed with SRT. Are you aware of this and what is your recommendation for practices? All bundled denials and remain denied after appeals. You recommended separate diagnoses, but patients do not always have another dx. Skip the EM billing or schedule visit on a separate DOS?
   
   25. Office visits are billable with the modifier 25.
   26. In 2019 Medicare issued a directive that E/M codes maybe billable with the treatment delivery of SRT.
   27. A separate and identifiable diagnosis code must be used when billing and E/M code.

4. If we have patients starting right after the first of the year, are we able to get PAs for the new codes prior to Jan 1st, or is it best to wait till after the new year?
   1. There is no specific information from CMS regarding treatment of multiple lesions on the same day.
   2. Currently we are recommending billing multiple lesions in units until otherwise notified by the insurance carriers.

5. If we are treating 2 sites on the same day, can we bill 2 units of 77439 ultrasound? Or can we only bill for one since this is one course since it is being treated on the same day?
   1. The ultrasound code currently states that you can only bill one unit per course of treatment. If two units of the CPT code 77437 (Treatment delivery) were performed, then it would seem reasonable that you could add the 77336 codes to each site treated.
   2. This will be monitored as we progress.

6. Our provider is interested in using diagnostic ultrasound codes such as 76536 for an ultrasound on the head/neck area. Any thoughts on that?
   1. No, this is not billable with SRT codes.

7. We previously were not treating Aetna nor AvMed patients because they were not getting approved…will this change?
   1. Now that CMS has designated specific CPT codes for SRT, we believe it will be more difficult for commercial payors to deny SRT as not medically necessary. As a result, we anticipate this will open the door for more patients with commercial insurance plans to receive SRT.
8. Do you have to be using ultrasound to bill 77436 each day? Or can you just bill it each day regardless?
   1. No, the ultrasound does not have to be performed to bill the 77436 simulation and treatment planning code.
   2. The 77436 codes should be billed when medically necessary.

9. Can a patient receive / be billed for a separate service in the office on the same day as the SRT treatment?
   1.  

10.  How often can we do 77436? Does that vary per insurance?
    1. Every time and it does not vary per insurance carrier at this time.
11. If a patient begins a treatment plan with two sites for twenty fractions, what are the billable codes that can be applied for each visit? Just want more clarification on this.
    1. Currently, the 77437 is billable per lesion, per fraction unlike the 77401-treatment code that specifically stated once per date of service.
    2. Currently the 77436 – per lesion/per fraction
    3. 77439 – ultrasound once per course of treatment
    4. 77336- physic oversight – once weekly.

12. Do you know if there will be any issues billing more than one treatment site per day with the same diagnosis code?
    1. MedIQ recommends using modifiers 59 or 76 on the second lesion when coding.

13. Will there be any global periods for these new codes?
    1. No, there should not be.

14. Should an E/M code be billed when we are doing the simulation visit?
    1. If the physician is evaluating the patient’s condition—such as assessing signs, symptoms, erythema, or radiodermatitis—then yes, an E/M code may be billed.
    2. The diagnosis of NMSC has already been confirmed by biopsy, and the medical decision to treat utilizing SRT is established. During the simulation visit, the lesion is defined by size and margin, and the prescription is written under CPT 77436. Once this treatment regimen has been established, ongoing evaluation and management should focus on documenting the lesion response to treatment.
    3. An office visit may be billed at each treatment session, or at a minimum during the 5th, 10th, and 15th fractions to demonstrate continuity of care.

15. Clarification on 77439 code. We can only bill once on complex Sim? If needed to monitor tumor progression, financial waiver to patient in which the cost is passed on to them?
    1. Ultrasound guidance is used during simulation and is valuable for determining the appropriate kV depth for treatment.
    2. If additional ultrasound imaging is required and the commercial insurance contract does not contain language prohibiting patient billing, the service may be billed directly to the patient. In this case, we recommend having the patient sign a financial waiver indicating they want the service performed.
    3. For Medicare patients, an ABN must be signed prior to performing and billing for the service.

16. How do we justify the 77436 daily if not using ultrasound?
    1. Remarking of the lesion site with margin for placement accuracy.
    2. Patient positioning
    3. Prescription changes due to increased biological responses.

17. I thought the insurance will not pay for the exam of a different problem on a day when we bill for SRT delivery.
    1. Although this has been difficult in the past with certain commercial carriers, it is allowable.
    2. The modifier 25 should be used with the E/M code on the same day as the treatment delivery for SRT.

18. Can you clarify or give examples on when a 77336 would be used?
    1. Please refer to question 16 for an answer.

19. Does the 77436 includes reverifying location for treatment?
    1. Please refer to question 16 for an answer.

 

20. So, what would the recommendation be for treating multiple lesions? Will we get authorization for number of treatments x number of sites moving forward?
    1. To date, CMS hasn’t defined the rules surrounding multiple treatment fields on a single patient. The Sensus Clinical Team recommends treating no more than two lesions to decrease the likelihood of medical error.
    2. Once the codes that require authorization are identified, it’s recommended to request as many authorizations as possible.

21. Do you know if commercial carriers are covering SRT fully now with more experience by CMS?
    1. To date, commercial plans have not released their policies concerning the new codes. The number of denials is expected to decrease with the introduction of these validated SRT codes.

22. What if they have prior auth but haven’t started until the new year? Re-do the PA with the new codes?
    1. It is recommended to continue using the current authorization on file. Medicare does not require prior authorizations, so beginning January 1, 2026, the new billing codes will go into effect.
    2. For commercial payors or plans that require prior authorization obtained in 2025, it is currently unclear whether a new authorization will be needed with the new codes or if the existing authorization should remain in place until the treatment plan is completed.

23. Do these codes apply for keloids?
    1. Yes, the CPT codes are dedicated for the use of SRT and are not defined by specific diagnoses codes.

24. Can you speak to remote supervision this year and in 2026?
    1. Rules surrounding remote supervision vary by state, so it is important to review and follow your state-specific regulations to ensure full compliance.
    2. Please also be aware that every state requires a licensed practitioner and/or a radiation therapist (RT(T)) to deliver a radiation dose.

25. Are there RVU’s for the new codes yet?
    1. Yes, the national average RVU’s can be found on the “2026 MedIQ Coding Guidelines”.

26. When billing 99212 does the provider have to be in the room with the patient or just on site?
    1. Yes, the 9921x codes are defined as a provider performing an evaluation and management of the patient’s condition and is categorized by the level of decision making involved.

27. The reimbursement is lower for these new codes than the ones that we are currently using, how would we make up the difference?
    1. The adoption of dedicated SRT codes may result in lower reimbursement per service, but these codes are likely to reduce previous limitations experienced with certain plans, effectively expanding the potential patient’s pool. With CMS-approved, validated codes for SRT, commercial payors and Medicare replacement plans will have more difficulty denying coverage, allowing providers to offer SRT to a larger number of patients. This broader access can help offset the lower per-service reimbursement.

28. If multiple lesions are being treated simultaneously, do we enter the quantity based on the number of lesions?
    1. To date, CMS hasn’t defined the rules surrounding multiple treatment fields on a single patient. Therefore, it’s recommended to enter the quantities to match the number of lesions to be treated.

29. We have been billing a 77280 as a “Remarking code” until patients have radiation dermatitis. Would we replace that with the 77436 going forward?
    1. Yes, the new code, “77436 superficial treatment planning and simulation-aided field setting” code will replace the “77280 Simple Simulation” code.

30. We were getting a few denials for global period violations related to SRT. Anyone having global period issues?  Some patients were seen for unrelated issues during SRT treatments and were denied.
    1. There are no global periods on E/M codes related to SRT codes.

31. If you have a remote MD monitoring PA and a RTT delivering the service, who are we billing under. Can we bill under the PA?
    1. It is recommended to verify your state’s guidelines regarding provider billing practices to ensure compliance.

32. Can you give an example of what codes to use for the first simulation visit? If it’s formerly a complex sim. Also does decay still have its own code?
    1. 77436 – Superficial treatment planning and simulation-aided field setting
    2. 77437 – Delivery of superficial radiation dose
    3. 77439 – Ultrasonic image guidance (if applicable)
    4. 99212, 99213, or 99214 – Office visit with varying levels of medical decision

33. If you have a cancer/keloid that is larger in size and needs to be treated in multiple sections, can you bill 77436 and 77437 for each section?
    1. No, a single field is being treated despite how many sub fields are required to fully treat the area.

34. Can you bill a simulation and a delivery on the same day with the new codes?
    1. Yes, we believe that you can. CMS has not published specific guidelines stating otherwise.

35. What if current software will not you use the old codes past 1/1/26?
    1. You may have to submit paper claims.

36. If the physics check is billed once a week but the patient is only treated twice a week, would we be able to be able to bill every two fractions or still every 5 fractions?
    1. According to the CPT codebook, 77336 (Physics Check) may be performed weekly. Our recommendation is to continue billing weekly until CMS or private insurance carriers issue guidance stating otherwise.

37. CMS NCCI edits do not permit an EM related to a procedure to be billed with Modifier 25. How are you justifying billing an EM?
    1. The new CPT codes for SRT are specific to the service and treatment of the lesion. Nowhere in the code descriptions is there mention of continuity of care or lesion management, which is why billing an E/M in conjunction with SRT is considered appropriate. In fact, CMS issued a ruling in 2019 supporting this practice. A copy of this letter is available on the SRT University website for reference.

38. Would we bill out a 77436 for treatment planning of a decay and/or gap boost?
    1. Yes, we believe this is allowable since there will be a change to the prescription due to the therapeutic factor (TFD) value change.

39. Do you know if these new procedure codes will be subject to the multiple procedure reduction rules?
    1. This has not been the case in the past it is something that we will need to monitor in the future.

40. What about the 77600 or Hyperthermia Treatment?
    1. Hyperthermia codes are not billable with SRT codes.

41. What is the code for a physics check which you are recommending that it be billed once per treatment for a specific diagnosis?
    1. The physic code 77336 is billed once per week during the course of treatment, not per

42. What code is replacing decay calculation and adjustment of treatment?
    1. The CPT code 77436 should be used in place of the 77300

43. If a dose and decay calculation has to be performed, what, if any charge would we use?
    1. See above

44. Would it be appropriate to bill an EM during simulation as well? What other problems would be appropriate to report at Sim? Further into treatment, we report rad derm, erythema, rash etc. ?
    1. Yes, billing an E/M during simulation is possible, depending on the physician’s discretion. Any separate assessment or evaluation performed during the simulation should be clearly documented. This may include evaluation of patient history, current signs or symptoms, or other clinical concerns relevant to the treatment plan.

45. We have a physicist who remotely checks QA monthly, would this count as something to bill code 77336 for? if so, what documentation is needed?
    1. The 77336 code is billable whenever a licensed physicist performs a chart check of a patient’s treatment plan. These checks can be conducted monthly, weekly, or as required by state regulations.
    2. If your practice uses the Sensus Sentinel system, the physicist’s checks can be documented and viewed directly through the platform. If your practice is not on Sentinel, you should coordinate with your physicist to determine the appropriate documentation required for billing.

46. Would we need a new authorization from a Commercial Insurance if it was obtained this year, but the patient does not start treatment until the new year?
    1. We currently do not have definitive clarification on this issue.
    2. If a patient is mid-treatment at the beginning of 2026, it may be appropriate to continue billing using the old codes associated with the existing prior authorization.
    3. If the patient has not yet started treatment but a prior authorization was obtained in 2025, we recommend contacting the payor for guidance on how to proceed.
    4. Please note that requirements may vary by payor.

47. Our physicist comes in every 6 months as required by state. So, we will be able to bill 77336 too?
    1. This visit would not qualify for billing CPT 77336 if the physicist is performing commissioning or recommissioning of the unit, which is required annually or, in some states, more frequently.
    2. CPT 77336 is only billable when a licensed physicist performs patient-specific chart checks, typically on a weekly basis, to ensure accuracy and appropriateness of the treatment plan. These chart checks must be documented as part of active patient treatment—not as part of routine machine commissioning.

48. So, one final clarification, it is OK to do 2 lesions at the same time starting next year, correct?
    1. Currently, there is no verbiage indicating otherwise. We will continue to monitor the situation as the new codes are implemented throughout the year.