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Radiotherapy

An overview of market access challenges for different modes of radiotherapy for cancer in European countries.

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Procedure coding

Procedure coding for radiotherapy (or radiation therapy) is well-established in European countries. The preparation and delivery of the radiotherapy are coded separately. Typically, the codes differ depending on the mode of delivery (external or internal) and type of radiotherapy (three-dimensional conformal radiation therapy, intensity-modulated radiation therapy, stereotactic radiotherapy, etc.). For example, in Sweden, intensity-modulated radiotherapy is specifically coded via a KVÅ code DV070 “Radiation therapy, IMRT (intensity modulated radiotherapy)”, whereas in England, a nonspecific supplementary code Y91.1 “Megavoltage treatment for complex radiotherapy” can be used in addition to codes for radiotherapy delivery to indicate the method. 

In some countries, coding for radiotherapy preparation or delivery might be complex, with multiple codes depending on the number of imaging techniques used for the preparation of radiotherapy or radiotherapy regimens. For example, in England, there are several OPCS codes for different modes of brachytherapy, including intracavitary (code X65.2), interstitial (code X65.2), and intraluminal brachytherapy (code X65.6). Supplementary codes are used to specify the high-dose-rate or low-dose-rate brachytherapy and the type of radioactive material (removable or non-removable). 

The use of certain types of radiotherapy can be limited by clinical indications. For example, in France, the use of CCAM code ZZNL050 “External Intensity-modulated radiation session using linear accelerator, without the target position control” for intensity-modulated radiation therapy is limited to head and neck tumors when protection of the salivary glands is necessary, tumors of the spine and tumors of the base of the skull and the vault, excluding high-grade glioma.

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Payment mechanism

As radiotherapy preparation and delivery is typically performed in outpatient specialist settings, the payment model depends on the payment system used in this type of setting: in England, France, the Netherlands, and countries of the Nordic region radiotherapy is reimbursed solely via the diagnosis-related group (DRG) mechanism, whereas in Belgium, Germany, Italy, Switzerland, the radiotherapy preparation and delivery services are reimbursed via a fee-for-service model via country-specific catalogs for outpatient specialist services.

In most European countries, radiotherapy planning and delivery are reimbursed separately. For example, in the Netherlands, there is a specific DRG 990061014 “Preparation for radiotherapy (irradiation)”; radiotherapy delivery is reimbursed via different DRGs depending on the radiotherapy type.
 

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Policy considerations

Due to its high medical and social importance, radiotherapy can be subject to specific policies from payers or national decision-makers in the countries where such frameworks exist. 

For example, in England, radiotherapy is commissioned by the national payer, NHS England, in terms of the National Program of Care “Cancer”. Clinical Reference Group “B01 Radiotherapy” of the National Program of Care “Cancer” is responsible for the development of the policy documents, including a service specification document “Radiotherapy (All Ages)” (2013) and “Stereotactic Radiosurgery and Stereotactic Radiotherapy (Intracranial) (All Ages)” (2019).

In some countries, national decision-makers can restrict reimbursement for certain types of radiotherapy to limited clinical indications or age groups. For example, in Germany, the Federal Joint Committee (G-BA) in 2022 decided that stereotactic radiosurgery for treating patients with operable brain metastases would be covered by statutory health insurance, as the result of the G-BA's evaluation of the method according to § 135 (1) Sentence 1 SGB V. 
 

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Health technology assessment

Due to established reimbursement in European countries, conventional radiotherapy methods in cancer have not become a subject of HTA in recent years. 

Novel regimens and approaches to radiotherapy delivery can become a subject of HTA. For example, in 2022, the German Institute for Quality and Efficiency in Health Care (IQWiG) published the HTA of stereotactic radiosurgery for treating operable brain metastases, which concluded that comparing single-stage stereotactic radiosurgery versus whole-brain irradiation, the evidence of a greater benefit of stereotactic radiosurgery was observed.

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Future challenges 

Radiotherapy in cancer has established reimbursement and funding in many European countries. However, novel regimens and approaches to radiotherapy preparation and delivery might require adjustment of payment mechanisms to fully leverage their unique technology or cost profile. 

MTRC has experience with more than 4 projects related to radiotherapy in Europe

News and insights

Med Tech-related health technology assessments in Wales in March-April 2026

In March-April 2026, Health Technology Wales (HTW) accomplished two full appraisals on salvage high-dose-rate brachytherapy for prostate cancer and AI-assisted ultrasound for the detection of deep vein thrombosis. Additionally, two Med Tech-related Topic Exploration Reports were published in the E-health and Pulmonology fields.

Work plan for the development of specialised commissioning policies updated in England

On March 31, 2026, NHS England released an updated work plan for the development of Clinical Commissioning Policies for specialised services. The update includes three new MedTech-related policies in the cardiovascular and radiotherapy areas, as well as the initiation of a revision to the existing policy on TAVI. No policies have been published since the previous update. The status of ongoing policies has been revised.

Ongoing HTA by the Scottish Health Technologies Group in March 2026

As of March 2026, the Scottish Health Technologies Group is working on health technology assessments in several areas, including diagnostic imaging, e-health, endoscopy, ENT, in-vitro diagnostics, and radiotherapy.

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