CY 2026 Medicare Physician Fee Schedule: What Interventional Radiologists Actually Won — and What Still Hurts

Section analysis by Elina Sabilova, CPC, CFPC, CPMA — Billing Department, WCH Service Bureau

EDITOR’S NOTE: The CY 2026 MPFS Final Rule was released October 31, 2025, effective January 1, 2026. This article focuses on the interventional radiology-specific provisions — both the genuine wins secured through SIR advocacy and the structural changes that still create real revenue risk. Numbers cited reflect national-level CMS estimates unless noted otherwise.

The Headline Number: IR Gets +2% While Diagnostic Radiology Takes -2%

CY 2026 MPFS Overall Specialty Impact (CMS Estimates, RVU-Based)

SpecialtyEstimated Impact
Interventional Radiology+2%
Diagnostic Radiology-2%
Nuclear Medicine-1%
Radiation Oncology-1%

Source: ACR preliminary summary, CMS CY 2026 MPFS Final Rule impact tables

The top line looks good for IR. A +2% swing in an era of consistent fee schedule erosion is genuinely meaningful, especially when placed against the backdrop of where the specialty has been: year after year of inflation-adjusted cuts, the steady migration of proceduralists into hospital employment, and a billing structure that has historically failed to capture the complexity of what interventional radiologists actually do in the cath lab and hybrid OR.

But the +2% aggregate masks a split that every IR physician in practice needs to understand. The site of service differential is stark, and it points to one of the larger structural tensions CMS has introduced for 2026.

The Site-of-Service Split: ASC vs. Hospital-Based Fees

ASC / Global Fees: +7%Hospital-Based Professional Fees: 7%
Increase due to higher global/globalized reimbursement alignment and ambulatory migrationDecrease due to site-of-service differential pressure and reimbursement shifting toward outpatient settings

The aggregate +2% for IR is a weighted average. Underneath it:

ASC and global fees: approximately +7%

Procedures performed in ambulatory surgery centers, with global billing (professional + technical component bundled), are rewarded in this fee schedule cycle. The new LER coding structure — discussed in detail below — was explicitly designed with the shift toward outpatient revascularization in mind, and the RVU values finalized by CMS reflect that setting bias.

Hospital-based professional fees: approximately -7%

This is the cut that drew significant pushback from specialty societies including SIR. CMS finalized a structural change to how it calculates practice expense (PE) RVUs for services delivered in the facility setting. The agency’s logic: physicians working in hospitals have their indirect overhead — space, equipment, non-physician staff — covered by the hospital’s cost structure. Therefore, CMS finalized a reduction of facility PE RVUs to half the corresponding non-facility PE RVU amount.

The problem, as SIR and others noted in comments, is that this model doesn’t reflect what actually happens operationally. Many independent IR groups work in hospital facilities without the hospital subsidizing their true overhead. The cut effectively penalizes the site of care rather than the physician’s actual resource utilization.

CRITICAL COMMENTARY: The +7%/−7% split has a strategic implication that goes beyond arithmetic: it accelerates an already-visible trend toward ASC migration for IR procedures. Drug-coated balloon angioplasty, tibial stent placement, venous access procedures — none of these require an inpatient setting. If reimbursement now meaningfully favors the ASC environment, expect practices to reorganize around outpatient settings where they have either ownership or contractual alignment. CMS is, intentionally or not, reshaping where IR work happens by pricing the settings differently.

The Big Structural Change: 46 New LER Codes Replace 6 Old Ones

This is the most operationally significant change in CY 2026 for IR practices, and it’s not primarily a reimbursement story — it’s a documentation and revenue integrity story.

What Changed

Effective January 1, 2026: CPT codes 37220–37235 (6 codes for lower extremity revascularization) — DELETED Replaced by 46 new codes: 37254–37299, organized by vascular territory. Any claim submitted with old codes for 2026 dates of service will be rejected automatically

The old coding structure was broad and procedure-type based: angioplasty, stent, atherectomy, with rough vascular territory distinctions. It was designed when fewer options existed and when the complexity stratification that defines modern LER work didn’t need to be captured in billing. That world no longer exists.

The New Architecture

The 46 new codes are organized across four vascular territories:

  • Iliac
  • Femoral/Popliteal
  • Tibial/Peroneal
  • Inframalleolar (new territory, not previously captured in CPT)

Within each territory, the same treatment hierarchy from the old codes is preserved:

  • Angioplasty alone
  • Stent placement ± angioplasty
  • Atherectomy ± angioplasty
  • Stent + atherectomy ± angioplasty

The critical new dimension: each treatment type is now further divided into “straightforward” (treating a stenosis) vs. “complex” (treating an occlusion). The inframalleolar territory can only be reported for angioplasty — no stent codes exist at that level, which reflects the current device landscape and will need to evolve as tibial and below-the-ankle stenting matures.

The new codes also bundle all procedural elements: selective catheterization, crossing the lesion, the endovascular intervention itself, intraprocedural imaging guidance including R&I, and completion imaging. This is a meaningful bundling change. Practices that previously reported add-on codes for imaging guidance will need to audit their existing templates and macros.

By the Numbers: What the Stenosis-vs-CTO Split Pays

RVU percentage swings are useful for actuaries, but they don’t tell a physician much about what this change does to an actual case. The table below translates the LER overhaul into the number that does land: approximate national Medicare reimbursement, before and after the code split. (Commercial payer impact is far harder to generalize — contracted rates vary too widely by payer and region to produce a comparable table here, so this comparison is Medicare-specific.)

Procedure2025 (single code)2026 — straightforward (stenosis)2026 — complex (100% CTO)
Iliac stent + balloon$3,369.31$4,245.56$10,042.10
Femoral stent + balloon$9,486.87$6,203.05$13,754.14
Femoral stent + balloon + atherectomy$12,116.67$12,227.99$18,348.86
Tibial stent + balloon$9,700.74$6,704.89$12,337.44
Tibial stent + balloon + atherectomy$12,714.81$12,170.69$18,077.59

Figures reflect approximate national Medicare reimbursement derived from CMS RVU data and the applicable conversion factor for the corresponding 2025 and 2026 LER codes. Actual payment varies by locality and site of service; practices should run their own numbers against their MAC’s locality-adjusted rates.

Two things stand out. First, straightforward stenosis cases didn’t get a uniform increase the way the +2% IR headline might suggest. Iliac stenting actually pays modestly more in 2026 (+26%), but femoral and tibial stenting without atherectomy pay meaningfully less than the old blended 2025 rate, down roughly 31% to 35%. Once atherectomy is part of the case, the 2026 stenosis rate lands close to flat against 2025.

Second, complex chronic total occlusion cases are where the real reimbursement is. Every territory pays more for a CTO in 2026 than the single 2025 code did, anywhere from about 27% to nearly 200% more, and the CTO rate runs 1.5 to almost 2.4 times the straightforward rate for the same territory and treatment combination. On a femoral or tibial stent without atherectomy, that’s the difference between roughly $6,200–$6,700 and $12,300–$13,800 for what is, on paper, the “same” procedure.

That gap is exactly why the documentation requirement in the new code set isn’t a technicality. A “complex” code only applies when the angiographic record actually supports a 100% chronic total occlusion — meaning no antegrade flow through the lesion — not a high-grade or near-occlusive stenosis that simply happened to be hard to cross. Billing the CTO code on a case the angiogram shows as severe stenosis is the kind of gap an auditor will catch immediately, because the dollar difference is large enough to be a flag on its own. The operative note needs to state the occlusion finding in terms that match the angiographic read, not just the physician’s impression of how difficult the case felt.

What CMS Finalized on RVUs and PE Inputs

CMS finalized the work relative value units (RVUs) and direct practice expense (PE) inputs for all codes in the LER family. This was the essential ask from SIR going into the final rule: that the RUC-recommended valuations would survive the rulemaking process intact. They did, with the drug-coated balloon and tibial stent modifications described below.

The finalization of both wRVUs and PE inputs for all 46 codes at once is significant. In prior code introductions, it wasn’t uncommon for CMS to finalize wRVUs but hold PE inputs for further review — creating a gap year where codes were underpaid because supply and equipment costs weren’t captured. That didn’t happen here.

The Drug-Coated Balloon and Tibial Stent Win: A Case Study in Why Comments Matter

SIR Advocacy Win — Direct Reimbursement Increase Following SIR member comments, CMS increased reimbursement for:

  • Two drug-coated balloon (DCB) supply codes
  • Two drug-eluting tibial stent supply codes Additionally: CMS finalized a new supply pack for angiography services — a direct result of detailed feedback submitted during the comment period.

This is worth pausing on, because the mechanism matters as much as the outcome.

CMS’s initial proposed values for drug-coated balloon and drug-eluting tibial stent supplies used cost inputs that didn’t accurately reflect what these devices actually cost to procure and deploy. Drug-coated balloons in particular occupy a peculiar pricing position: they represent substantially higher device cost than bare-metal alternatives, but the clinical benefit (reduced restenosis, fewer re-interventions, better limb salvage in PAD) is well-documented in the literature. Underpricing the supply component creates a structural disincentive to use the higher-cost, better-evidence device — which is exactly the wrong policy signal in a specialty that’s been fighting to shift PAD care toward limb-preserving, office- and ASC-based interventional treatment.

After considering comments from SIR and others, CMS increased reimbursement for two drug-coated balloon supplies and two drug-eluting tibial stent supplies. CMS also finalized the inclusion of a new supply pack for angiography services, a direct result of advocacy and detailed feedback.

The angiography supply pack is less visible but practically important. Angiography is performed in essentially every LER case as the diagnostic roadmap and completion imaging. Having a finalized supply pack means the consumable costs associated with diagnostic imaging are captured in the direct PE inputs — rather than being absorbed by the practice as overhead.

Endovascular Therapy With Imaging: The RUC Wins

Following SIR and other stakeholder input, CMS revised its proposals and finalized the Relative Value Scale Update Committee (RUC)-recommended work RVUs. Additionally, CMS reversed its initial proposal and accepted the RUC-recommended values for the vascular interventional technologist clinical time — another major win for the IR community.

The vascular interventional technologist (VIT) item deserves attention. In the proposed rule, CMS had contested the RUC’s valuation of clinical time for the VIT — the specialized tech who scrubs in on endovascular procedures. This isn’t a minor ancillary position. The VIT manages the equipment cart, exchanges devices during the procedure, and maintains sterile field integrity throughout cases that can run 90 minutes or longer. Undervaluing their time in the PE inputs would have understated the true resource cost of the procedure.

CMS reversing course and accepting the RUC-recommended VIT values is a methodological win as much as a financial one: it signals that the PE input modeling will reflect real-world staffing requirements for complex endovascular work.

Prostate Biopsy: A Quiet Addition to the IR Win Column

CMS finalized the RUC-recommended wRVUs and direct PE inputs for prostate biopsy, ensuring accurate valuation and recognition of the work involved in these procedures.

Nine new prostate biopsy codes were introduced in CY 2026 (CPT 55707–55715), covering:

  • Transrectal and transperoneal approaches
  • Sextant biopsy with and without MRI-fusion guidance
  • Target lesion biopsies

For IR practices that have built out prostate biopsy programs — particularly MRI-fusion guided biopsy, which has become the standard of care in many academic and large community settings — accurate valuation here translates directly to practice sustainability. MRI-fusion biopsy is resource-intensive: it requires co-registration software, specialized ultrasound equipment, and physician training. The previous codes didn’t adequately capture that complexity.

Quality Payment Program: The IR MVP Goes Live

New for 2026 Performance Year: IR MIPS Value Pathway (MVP) finalized as a voluntary reporting option. Includes:

  • 6 MIPS quality measures + 4 QCDR quality measures
  • 19 improvement activities
  • 3 cost measures
  • 7 new quality measures added to the IR specialty measure set following SIR feedback

The IR MVP formalizes a quality reporting pathway specifically designed for interventional practice — moving away from the generic multispecialty MIPS measure set toward metrics that actually reflect what IR does and what matters to IR patients.

The voluntary nature for 2026 is intentional: it gives practices a year to understand the measure specifications, build documentation workflows, and evaluate their performance before mandatory reporting cycles. Practices that engage early will be better positioned when the landscape shifts.

What Else Changed: Supervision Flexibilities Made Permanent

One change that received less coverage but has real operational significance: the MPFS Final Rule makes permanent the supervision flexibilities granted in 2020 during the COVID-19 pandemic. Physician offices and Independent Diagnostic Testing Facilities (IDTFs) will have the ability to directly supervise certain diagnostic tests, such as Level 2 contrast administration, using real-time audio and visual interactive telecommunications technology. Note that both audio and video are required; audio-only connectivity is not sufficient.

For IR groups operating multiple sites or supervising diagnostic testing across a distributed practice model, this is meaningful. The requirement for simultaneous audio and video rules out informal phone check-ins, but real-time two-way video is achievable on standard tablet hardware. Practices that built these workflows during the pandemic can now rely on them as permanent policy, not annually renewed waivers.

The Honest Accounting: What Still Hasn’t Been Fixed

Wins are real. The structural headwinds are also real, and it would be a disservice to the readership to bury them.

The facility PE RVU cut is in effect. Hospital-based IR — particularly at independent groups contracted into health system facilities — absorbs a meaningful reimbursement reduction that the +2% aggregate headline doesn’t fully offset. Groups in this arrangement need to model the impact on their top procedures.

The LER code transition creates near-term revenue cycle risk. Claims submitted with deleted codes 37220–37235 for 2026 dates of service will be rejected. The operational window to update EHR templates, billing system crosswalks, pre-authorization request formats, and documentation macros was tight. Practices that haven’t completed this audit by now should treat it as a priority, not a background IT project.

The APM split disadvantages most community IR practices. Two conversion factors now exist: $33.57 for qualifying APM participants and $33.40 for everyone else. Many radiology practices are unable to participate in Alternative Payment Models (APM) as part of the Quality Payment Program (QPP), so it’s likely that most practices will receive reimbursement at the lower of the two rates for 2026.

The efficiency adjustment is a structural policy shift. CMS finalized a 2.5% efficiency adjustment applied to work RVUs and intraservice physician time for non-time-based services. The logic: physicians become more efficient as they perform a procedure repeatedly, so the RVU value should decline over time to reflect that efficiency gain. The adjustment will be applied every three years going forward. For high-volume procedures like venous access or peripheral angioplasty, this creates steady downward RVU pressure that advocacy will need to address at each cycle.

Practical Takeaways for IR Practices

Audit your LER documentation templates immediately. Old CPT codes 37220–37235 are invalid for any 2026 date of service. Your operative note macros need to capture: specific vascular territory, whether the lesion was stenosis (straightforward) or occlusion (complex), the specific intervention performed, and that imaging guidance was performed as part of the procedure. Claims using old codes are rejected at the MAC level; there is no grace period.

Model your hospital-based vs. ASC volume separately. The −7%/+7% site differential means your blended rate depends entirely on where your cases are done. If you haven’t mapped your procedure mix by site of service, do it now, before interpreting what the +2% aggregate means for your practice’s actual revenue.

Verify your DCB and tibial stent supply codes are updated. CMS increased reimbursement for specific supply codes within the LER family following SIR comments. These increases are only captured if your billing system reflects the finalized 2026 PE inputs. Confirm with your billing vendor or RCM team that supply code crosswalks are updated.

Engage with the IR MVP in 2026. Voluntary reporting now gives you a runway to understand your performance before the stakes increase. Six MIPS quality measures and four QCDR measures were designed with IR workflows in mind; they’re achievable with structured documentation. Engage before it’s required.

Verify virtual supervision protocols are formalized. If your practice supervises diagnostic tests across multiple sites, the permanent telehealth supervision flexibility applies, but it requires simultaneous audio and video. Document your protocol, verify your technology meets the standard, and train supervising physicians on the requirement.

Track the HOPPS/ASC final rules. The Hospital Outpatient Prospective Payment System and ASC final rules for CY 2026 were released separately. SIR’s Economics Steering Committee analysis should be reviewed alongside this MPFS summary; ASC payment rates for IR procedures are not covered in the MPFS and may contain additional changes relevant to practices shifting volume toward outpatient settings.

The Larger Context: Why 2026 Matters as a Pivot Year

The CY 2026 fee schedule isn’t just an annual billing update. It represents a policy posture that will shape IR practice models for the next three to five years.

CMS is, through differential site-of-service pricing, nudging proceduralists toward ASC and office-based lab (OBL) settings. That signal is consistent with a decade-long CMS effort to shift outpatient volume away from the hospital outpatient department (HOPD) environment. For IR, this is actually strategically aligned: most peripheral vascular work, venous procedures, and increasingly oncologic interventions don’t require the support infrastructure of an inpatient or even HOPD setting.

The LER code overhaul — despite its transition complexity — is the right policy direction. The old six-code structure was a relic that couldn’t distinguish between a straightforward iliac stenosis angioplasty and a complex below-knee occlusion requiring atherectomy. The new 46-code architecture, organized by territory and lesion complexity, finally gives interventional radiology a coding vocabulary that matches the clinical sophistication of the work. Getting the RVU and PE input valuations right from day one, with supply code corrections for DCB and tibial stents, means the foundation is solid.

The risk is implementation. Revenue cycle disruption from the LER code transition, combined with PE RVU reductions for hospital-based work, creates a scenario where a well-structured fee schedule win on paper translates into a rough first two quarters in cash flow. The practices that come through 2026 in good shape will be the ones that treated the coding transition as a clinical operations project, not just a billing office update.

References & Sources

Content reflects the CY 2026 MPFS Final Rule as released October 31, 2025. HOPPS and ASC final rules for CY 2026 are covered in a separate section. CPT® is a registered trademark of the American Medical Association.


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