Legislation & Regulations That Could Affect Radiology Practices

H.R. 8163, the Provider Reimbursement Stability Act of 2026

Medicare payment reform is one of the highest priorities facing physicians. Although the basic Medicare fee schedule was increased for 2026 by 3.26% for non-Qualified Professionals, it is still more than 7% lower this year than it was 10 years ago. The Provider Reimbursement Stability Act of 2026 (H.R. 8163) that is currently pending in Congress has 36 co-sponsors and it is supported by all the major radiology specialty societies as well as those of many other medical specialties and state medical societies. The bill contains several provisions that would improve the annual adjustments to the Medicare Physician Fee Schedule to make it a more realistic when compared with current economic trends, including:

A two-year lookback period to correct utilization estimates for newly unbundled codes.
Simultaneous update of all direct cost inputs at least once every five years in consultation with specialty societies.
Adjusting the budget neutrality threshold from 20% (set in 1992) to 54.3% beginning in 2027 and indexing it to the Medicare Economic Index (MEI) every five years.
A cap of 2.5% on the year-to-year variance of the conversion factor, excluding statutory increases for the Quality Payment Program or future MEI adjustments.

The bill has advanced out of the House Ways and Means Committee and is set for consideration by the full House. Radiologists can support H.R 8163 by contacting their representatives.

Medicare Access to Radiology Care Act (MARCA) of 2026

MARCA was first introduced in the Senate in 2024 but failed to move ahead. An updated version was re-introduced on May 21, 2026. The bill would allow physicians to submit claims to Medicare for nondiagnostic services performed by registered radiologist assistants (RA) under direct supervision of a physician. If passed it could help ease the shortage of radiologists nationwide. According to an article by Thomas Greeson of ReedSmith, the new draft is improved in that it no longer ties billing rules defining “incident to” services to the payment for RA services. Greeson points out that the bill does not provide coverage for office-based services, but that this is likely an oversight that could be corrected as the bill moves forward.

This bill is one to watch as it moves through the Senate committees.

H.R. 4710 / S. 2420, the No Surprises Act Enforcement Act

Specialty societies and state medical societies joined the Medical Group Management Association (MGMA) in a letter of support for this bill that would address an unintended consequence of the No Surprises Act (NSA). The Independent Dispute Resolution (IDR) process of the NSA was intended to provide an equitable solution when payers and physicians could not agree on a reasonable rate for out-of-network services. However, health plans have failed to make payment to physicians within the statutory 30-day period following an IDR determination when they are the losing party. The pending legislation would authorize penalties on any party that does not adhere to the statutory timelines following an IDR determination.

Radiologists are encouraged to contact their representatives in both the House and Senate to urge passage of H.R. 4710 and S. 2420.

H.R. 5737 / S. 1692, the Radiology Outpatient Ordering Transmission (ROOT) Act

The American College of Radiology (ACR) urges radiologists to support the ROOT Act, which would resurrect the requirement for ordering physicians to consult Appropriate Use Criteria (AUC). The AUC/CDS requirement was included in the Protecting Access to Medicare Act (PAMA) of 2014, but it was subsequently removed from implementation by CMS due to administrative hurdles. The ROOT Act purports to simplify those administrative issues and allow implementation of a system based on physician-developed criteria. The PAMA of 2014 imposed a financial penalty on the radiologist for failure of the ordering physician to consult a Clinical Decision Support (CDS) system, but it is unclear how this revised rule would be enforced.

Prior Authorization Reform

Two bills are pending that intend to rein in utilization management practices employed by Medicare Advantage (MA) plans. H.R. 3514 / S. 1816, Improving Seniors’ Timely Access to Care Act, would require Medicare Advantage plans to implement electronic prior authorization systems, standardize electronic transactions, reduce decision turnaround times, and increase transparency around approval and denial rates. H.R. 8375 / S. 4384, Medicare Advantage Improvement Act, would provide tighter oversight of MA plans, standardize coverage criteria, and promote faster authorization and more transparency. S. 3762, Prior Authorization Relief Act that was introduced in the Senate would eliminate or reduce prior authorization requirements for clinicians in value-based payment models.

Other Areas to Watch

Aside from Congressional action, CMS rulemaking can have a serious impact on reimbursement and administrative burdens for radiology practices. We annually review the Medicare Physician Fee Schedule, which is proposed in July and finalized in November for the coming year. Among the areas that could be impacted are:

Quality Payment Program changes, including the development of specialty-specific MIPS Value Pathways
Site-Neutral Payment Expansion, which would continue to shift Medicare reimbursement in favor of non-hospital settings such as imaging centers and Office-Based Labs.
Addition of imaging services to the prior authorization demonstration models.

Conclusion

Healthcare Administrative Partners is constantly monitoring the regulatory landscape to keep you abreast of issues that will affect your practice. You can participate by contacting your representatives about issues you feel are important. Stay connected to the issues by subscribing to this blog.

Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.

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