- Home
- HAP Radiology Billing and Coding Blog
- What’s HAPpening in Radiology – Q3, 2026
What’s HAPpening in Radiology – Q3, 2026
Healthcare Administrative Partners (HAP) continually monitors issues that affect your practice’s reimbursement.
Here is a compilation of our latest items:
No Surprises Act IDR Rules Change
Beginning November 1, 2026, the Independent Dispute Resolution (IDR) process will transition from single-use web forms to a new Gateway platform for managing disputes under the No Surprises Act (NSA). Note that the IDR process is only to be used for disputed claims where the radiology group is out of network, it may not be used for changing rates under existing managed care agreements. Users may sign up for access to the Gateway as of September 15, 2026.
Along with the Gateway comes other positive changes, including:
- The ability to batch up to 50 qualified services rather than the previous limit of 25 services;
- Reduction of the filing fee from $115 to $15 per dispute; and
- Specific coding to be used by payers to better explain the basis for their payment determination.
The new rule provides that cases may be batched based on:
- Items and services furnished to a single patient on the same or consecutive dates of service and billed on the same claim form;
- Items and services furnished to one or more patients and are billed under the same or a comparable code; or
- Radiology, anesthesiology, pathology, and lab items and services that are furnished to one or more patients under service codes belonging to the same Category 1 CPT code section.
UHC Removes Prior Authorization Requirements
United Healthcare (UHC) is eliminating prior authorization for over 1,700 diagnosis and procedure codes, which they say will lead to removal of prior authorization for 30% of all healthcare services by the end of the year. The change will take place on a state-by-state basis beginning October 1, 2026, for 11 states. Our review of the coding changes shows very few codes that will affect either diagnostic or interventional radiology.
Medicare Payment for Use of Artificial Intelligence
The Inpatient Prospective Payment System (IPPS) rule for 2027 will include reimbursement to hospitals for their use of the CARE Multi-Triage CT Body tool that flags potentially urgent findings such as appendicitis or a bowel obstruction. The IPPS does not provide any professional component reimbursement to radiologists using the program.
The Future of Reporting in the Quality Payment Program
Traditional MIPS reporting will most likely be replaced in 2029 by the mandatory use of MIPS Value Pathways (MVP) for practices that are not participating in an Advanced Payment Model (APM). APM’s have been unavailable to many diagnostic radiology groups, and the MVP’s currently available do not provide radiology with a useful track. Traditional MIPS will continue to be available for 2027. Four measures have been reweighted, which could allow for higher scoring by radiology practices without using quality measures outside the radiology-specific measures.
Legislative Activity
Two bills of interest to radiology practices are pending in Congress. The Medicare Access to Radiology Care Act (MARCA) remains in committee in both the House and Senate. The legislation would allow payment to a supervising radiologist for qualifying Radiology Assistant (RA) services furnished in certain facility settings. The bills would define “radiologist assistant services” as services that would be physician services if furnished by a physician, are performed by an ARRT-certified RA under a radiologist’s supervision, are authorized under applicable state law, and are not separately billed or paid to another provider. As discussed in an article by Tom Greeson of ReedSmith, neither bill provides for payment in physician office settings.
The Patients Deserve Price Tags Act (PDPTA) was introduced in the House in 2025 and a companion bill in the Senate on July 27, 2026, and both remain in committee. If passed, this legislation would require disclosure of fees as well as ownership and investor information, which would impact outpatient imaging centers more than hospital-based practices.
We will continue to monitor progress on these bills and any others that might affect your practice.
Next Update
Watch for our next quarterly update at the end of December and be sure to subscribe to this blog to stay abreast of the many changes that affect your radiology practice.
Related Articles
Pluses and Minuses in the Medicare Physician Fee Schedule Proposed Rule for 2027
What's HAPpening in Radiology - Q2 2026
Legislation & Regulations That Could Affect Radiology Practices
Copyright © 2026 Healthcare Administrative Partners. All Rights Reserved.

Leave a Reply