ATTN Nevada:
Ann Jensen
Medicaid Administrator
State of Nevada, Dept. of Health & Human Services; Division of Health Care Financing & Policy
1100 East William Street, Suite 101
Carson City, NV 89710
ajensen@nvha.nv.gov
Re: Urgent Request to Update and Correct Medicaid Payment Rates for Radiation Oncology Services – CPT® Codes 77387, 77402, 77407, and 77412
Dear Medicaid Administrator:
I am writing to you in my capacity as Chairman of R3 and CEO of RC Billing with clients in Nevada to express grave concern regarding the current Nevada reimbursement rates for essential radiation oncology treatment delivery and guidance services. These outdated rates are unsustainable, severely undermine the financial viability of providing high-quality radiation therapy, and place timely access to care at serious risk for Nevada beneficiaries who require this life-saving treatment for cancer if these facilities are forced to halt services.
The rates for the revised radiation treatment codes are as follows:
· CPT 77387 (IGRT): $ NOT LISTED ON FEE SCHEDULE
· CPT 77402 (Rad treatment delivery, Level 1): $147.79
· CPT 77407 (Rad treatment delivery, Level 2): $268.35
· CPT 77412 (Radtreatment delivery, Level 3): $254.74
These rates are catastrophically low and do not come close to covering the actual costs of delivering safe, precise, and effective radiation therapy. Radiation oncology requires substantial capital investment in linear accelerators, imaging systems, quality assurance, physics support, and highly trained clinical staff. At these reimbursement levels, practices cannot absorb the ongoing operational expenses, leading to reduced capacity, delayed treatments, or complete discontinuation of services for Nevada patients in many communities. This directly jeopardizes patient outcomes in a vulnerable population that already faces barriers to care.
By comparison, national Medicare benchmarks for these same services (updated effective January 1, 2026, under the revised CPT coding structure that bundles technical image guidance into the delivery codes) are substantially higher and reflect the true resources involved:
· CPT 77387 (pro component only): approx $36.74
· CPT 77402 (Level 1): approx $79.49 (PFS non-facility) to $104.24 (HOPPS)
· CPT 77407 (Level 2): approx $317.64 (PFS non-facility) to $394.05 (HOPPS)
· CPT 77412 (Level 3): approx $391.46 (PFS non-facility) to $564.51 (HOPPS)
Nevada’s rates are lower than Medicare’s creating an untenable disparity. Many commercial payers reimburse at even higher levels. These national rates, while not extravagant, at least allow practices to maintain operations and invest in modern technology required for accurate, image-guided treatment.
The situation is urgent. Radiation therapy is a cornerstone of curative and palliative cancer care in which approximately 60% of cancer patients receive radiation therapy at some point in their treatment journey. Inadequate reimbursement threatens provider participation in Nevada networks, reduces geographic access (particularly in underserved areas), and risks poorer survival outcomes and increased downstream costs to the state from unmanaged disease progression.
We respectfully request that your appropriate team immediately review and align Nevada payment rates for CPT codes 77387, 77402, 77407, and 77412 with national Medicare benchmarks (or a reasonable cost-based equivalent) to ensure continued access to these critical services.
We are available to provide additional data, cost analyses, or meet with your team to discuss this matter promptly. Thank you for your immediate attention to this critical patient-access issue. We look forward to your response and collaborative action to protect Nevada beneficiaries’ access to radiation oncology care.
Sincerely,
Ron DiGiaimo MBA FACHE
Chairman of R3 and CEO of RC Billing
ron.digiaimo@rccsinc.com
@OfficialRCCSInc