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For CY 2026, except where otherwise indicated, we proposed to continue our policy and use the costs derived from CY 2024 claims data to set the proposed CY 2026 payment rates for brachytherapy sources because we proposed to use CY 2024 data to set the proposed payment rates for most other items and services that would be paid under the CY 2026 OPPS

Commenters also cited the technical and operational challenges of implementing the Excessive Radiation eCQM as a rationale for supporting voluntary reporting

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As Kennedy himself acknowledged during the February 2026 announcement, the Category 2 designations effectively created and accelerated the very gray market they were designed to prevent