The landscape for billing and coding Superficial Radiation Therapy (SRT) is undergoing a significant shift. With the 2026 CPT code updates, the American Medical Association has completely restructured how these services are reported, directly impacting reimbursement and compliance protocols for dermatology practices.
At Compass Healthcare Consulting, we specialize in helping practices like yours adapt to complex coding changes and maintain stringent billing compliance, while ensuring your practice knows how to code for every service rendered and properly documented. This deep dive into the 2026 SRT updates will help you prepare for a smooth transition and protect your practice’s financial health.
A Complete Restructuring: Understanding the 2026 SRT Code Family
Historically reported with codes including 77401 (treatment) and G6001 (ultrasound guidance), SRT services now fall under a newly created section in the Radiology chapter of CPT®: Surface Radiation Therapy (SRT). This new family encompasses both superficial radiation therapy and orthovoltage x-ray services. This new family of codes are intended to be used for superficial radiation therapy for skin cancer. While some of the codes previously used for SRT have not been deleted, they are intended for other types of radiation therapy and reporting these codes for SRT is not consistent with stated purpose of creating the new family of codes.
The table below outlines the fundamental shift from historical to new coding structures:
| Service | New Code(s) | Key Change & Compliance Note |
| Treatment Planning & Simulation | 77436 | Combines previous planning codes (77261–77263, billed once per course) and simulation code (77280, often billed multiple times per course of treatment in pre-2026). Now billable only once per course of treatment. |
| Treatment Delivery, Per Fraction | 77437 | Replaces deleted code 77401. Includes a significantly higher reimbursement per unit. |
| Image Guidance for Cutaneous Tumors | 77439 | Replaces G6001. Important: Image guidance is now allowed only once per entire treatment course, not per fraction. |
| Device Construction | 77332–77334 | Cannot be reported with codes 77436, 77437, or 77439. Typically performed on the same day as planning. |
| Dosimetry | 77300 | Not reportable with new SRT codes unless performed on a separate date of service. |
Important Note on Treatment Management (CPT 77427): This code, billed by some SRT providers every five visits, cannot be billed on the same day as treatment delivery (77437). Compass analysis has historically found that the management services documented are often more appropriately billed with an office visit code (e.g., 99212-99213), per CMS guidelines.
Reimbursement Impact: A Substantial Shift for Practices
Our analysis comparing 2025 national Medicare rates under historical coding to projected 2026 rates under the new structure reveals a stark financial impact. Using a conservative, compliant coding model (e.g., limited simulations, appropriate office visits for management), we project a potential reimbursement reduction of approximately 64% per typical treatment course.
- Estimated Total Reimbursement per Course (2025 Model): ~$7,400
- Estimated Total Reimbursement per Course (2026 Model): ~$2,700
This dramatic shift underscores the urgent need for practices to monitor their SRT billing patterns under the new system, understand the new coding logic, and adjust their financial forecasting accordingly.
Supervision Clarification: Navigating “Direct” vs. “Direct Personal” Supervision
Payors view skin substitutes as a significant expense and require conclusive proof that they are the appropriate, cost-effective solution as compared to other options. Documentation of medical necessity should include:
A pivotal update is the permanent adoption of “direct supervision” definitions that allow physician immediate availability via audio/video real-time communications in office settings.
However, for radiation therapy services, the Medicare Benefit Policy Manual requires “direct personal supervision.” While the wording is similar to the Medicare manual, this slight variation has caused confusion. Based on our interpretation and consistent with ASTRO: Supervising providers must be physicians (MD/DO); non-physician practitioners cannot supervise.
Given that SRT codes do not have a global surgery indicator of 010 or 090, it is defensible to utilize audio/video real-time technology for supervision, as the physician must still be immediately available to provide assistance and direction.
Actionable Steps for Your Practice
Conduct an Audit in 2025: Review SRT billing early in 2026 to ensure correct use of the new codes.
Update Your Practice Management System: Ensure your billing system reflects the new code family (77436, 77437, 77439) and deletes the old ones.
Revise Documentation Protocols: Train clinicians and coders on the new requirements, emphasizing that planning and simulation (77436) and image guidance (77439) are one-time-per-course services. Strengthen documentation for standalone office visits if management services are provided.
Financial Remodeling: Work with your financial team to project the impact of these changes on your practice’s revenue and adjust budgets or service offerings as needed.
Clarify Supervision Policies: Formalize your supervision policy for SRT in the office, ensuring it meets the “direct personal supervision” standard with clear protocols for audio/video availability of the supervising physician.
Partner with Compass for a Compliant Transition
Navigating this coding overhaul requires expertise. Missteps can lead to significant revenue loss or compliance risks. The consultants at Compass specialize in coding and billing compliance for healthcare practices. We can help you:
- Perform a detailed impact analysis.
- Develop compliant billing protocols.
- Train your administrative and clinical staff.
- Ensure your practice is prepared for going into the new year.
Have questions about implementing these 2026 changes?
Contact Jennie Hitchcock, President of Compass, at jhithcock@compassir.com or click to to book a virtual meeting with Jennie.
Disclaimer: This information is for educational purposes and based on preliminary code releases. It does not constitute legal or medical coding advice. Final code descriptors, guidelines, and payer policies should be consulted prior to billing. © 2024 Compass Healthcare Consulting. CPT is a registered trademark of the American Medical Association.
