Radiology Legislation Playbook 2026

Radiology is fighting four legislative battles at once. Here is what is actually at stake. 🏥

The Medicare fee schedule went up 3.26% in 2026. Sounds like progress. It is not. According to BC Advantage, that rate is still more than 7% lower today than it was 10 years ago.

Meanwhile, four separate bills are moving through Congress right now, and most radiology operators I talk to know maybe one of them.

Here is the full breakdown.

📋 The 4-Bill Radiology Legislation Framework (Summer 2026)

1. H.R. 8163, Provider Reimbursement Stability Act of 2026
This is the big one. It targets the structural math problem inside the Medicare Physician Fee Schedule.

Key provisions:
– Two-year lookback period to correct utilization estimates for newly unbundled codes
– Mandatory update of all direct cost inputs at least once every five years, in consultation with specialty societies
– Budget neutrality threshold adjusted from 20% (set in 1992) to 54.3% beginning in 2027, indexed to the Medicare Economic Index
– A hard cap of 2.5% on the year-to-year variance of the conversion factor

Status: 36 co-sponsors, passed out of the House Ways and Means Committee, awaiting full House vote.

This one matters most. The budget neutrality offset mechanism is why pay cuts compound over time. Fixing the threshold is the structural change, not just another one-year patch.

2. MARCA, Medicare Access to Radiology Care Act of 2026
First introduced in 2024, reintroduced May 21, 2026. If passed, it would allow physicians to bill Medicare for nondiagnostic services performed by registered radiologist assistants (RAs) under direct physician supervision.

Why it matters for workforce:
No new radiologists get trained overnight. RAs already exist in the system. This bill does not solve the shortage, but according to BC Advantage, it could help ease it by unlocking reimbursement that currently does not exist for RA-supported workflows.

One known gap in the current draft: it does not cover office-based services, which the article notes is likely an oversight.

3. H.R. 4710/S. 2420, No Surprises Act Enforcement Act
The IDR process under the No Surprises Act was supposed to resolve out-of-network payment disputes. The problem: health plans are not paying within the statutory 30-day window after losing an IDR decision.

This bill would authorize financial penalties on any party that misses those statutory deadlines. Radiology groups with significant out-of-network volume have real money sitting in limbo because of this enforcement gap.

4. H.R. 5737/S. 1692, ROOT Act
Would revive the Appropriate Use Criteria (AUC) requirement from PAMA 2014, which was removed by CMS due to administrative hurdles. The ROOT Act attempts to simplify implementation and create a physician-developed criteria system for imaging orders.

Note: the original PAMA penalty for failure to consult a Clinical Decision Support system fell on the radiologist, not the ordering physician. Enforcement in the revised version remains unclear.

📌 Save this framework. If you are heading into a budget conversation, a payer negotiation, or a practice strategy session, these four bills represent the four levers: rate stability, workforce capacity, cash collection, and utilization management.

The stakes here are not abstract.

A 7% real-dollar decline over 10 years means a group that was earning $10M in Medicare revenue in 2016 is effectively earning $9.3M today in purchasing power, before accounting for any cost inflation. The Provider Reimbursement Stability Act would not reverse that, but it would stop the bleeding.

MARCA does something different. It recognizes that you cannot close a radiologist gap with tuition loans. You close it by changing who can bill for which services inside the existing workforce.

👉 Follow Jonathan Govette, CEO of Oatmeal Health, for daily healthcare insights on LinkedIn. Deeper dives in The Oatmeal Bite on Substack: https://news.oatmealhealth.com