Section analysis by Elina Sabilova, CPC, CFPC, CPMA — Billing Department, WCH Service Bureau
Editorial note: This article reflects CMS Physician Fee Schedule 2026 data, summer 2026 radiology practice management analysis, and MARCA legislation status as of mid-2026. Legislative status may have changed after publication date; verify current bill status through congress.gov. This article is for informational and educational purposes and does not constitute legal, financial, or compliance advice.
Summer 2026 has produced two distinct but interacting stories for radiology practice economics. The first is the site-of-service payment analysis that radiology groups across the country are completing as mid-year financial data becomes available — an analysis that is confirming a pattern of non-facility payment gains in diagnostic and interventional radiology procedure categories that partially offsets the facility-setting reimbursement pressure documented earlier in this journal. The second is the continued progress of the Medical Imaging and Radiation Therapy Advancement Act — MARCA — through the legislative process, a bill that carries significant workforce and scope-of-practice implications for radiology practices that depend on radiologist assistant utilization for non-physician imaging supervision and performance.
Site-of-Service Shifts: What the Summer Data Is Showing
The summer 2026 radiology practice management analysis that specialty consultants and the ACR practice economics team have been conducting against mid-year collections data is producing findings that are more nuanced than the headline reimbursement narrative suggests. While the facility-based reimbursement pressure documented in the radiology section earlier in this journal — RVU reductions for hospital outpatient and facility-setting radiology procedures — is real and measurable, the non-facility payment picture is different in character. Office-based and outpatient imaging center settings are showing payment gains in specific procedure categories where CMS’s 2026 practice expense RVU adjustments have improved the non-facility component of physician payment.
The procedure categories where non-facility gains are most significant in radiology are concentrated in diagnostic imaging supervision and interpretation services performed in outpatient imaging center settings, and in interventional radiology procedures performed in office-based laboratory or freestanding ASC environments. For diagnostic radiology groups that operate or partner with freestanding imaging centers — rather than relying exclusively on hospital outpatient department settings — the 2026 rate structure creates a more favorable financial environment for the outpatient freestanding model than existed under prior-year rates.
The interventional radiology dimension of this analysis is particularly significant and connects directly to the broader cardiovascular OBL/ASC migration trend documented in the cardiology section below. IR procedures performed in office-based laboratories — peripheral vascular interventions, venous access procedures, pain management injections, and select neurointerventional procedures — are benefiting from non-facility practice expense RVU values that produce physician payment rates above facility-equivalent rates for the same procedure. For IR practices that have been building OBL infrastructure or considering it, the 2026 rate analysis provides updated financial modeling inputs that strengthen the non-facility business case for a broader range of procedure categories than prior-year analysis supported.
The facility cuts dimension of the summer analysis reflects the ongoing OPPS rate pressure on hospital outpatient radiology services — a dynamic that has been consistent across multiple years and that is continuing in 2026 with site-neutral payment policy developments affecting hospital outpatient imaging reimbursement in ways that make hospital-employed radiology economics increasingly dependent on volume rather than rate improvement. Radiology groups with significant hospital outpatient exposure — particularly those with exclusive hospital contracts — are modeling the long-term trajectory of hospital outpatient radiology economics with greater concern in summer 2026 than they were twelve months ago.
The Strategic Implication: Office-Based IR and the Diagnostic Outpatient Model
The summer 2026 site-of-service analysis is producing a consistent strategic signal for radiology practices: the financial case for non-facility procedure delivery has strengthened under the 2026 rate structure, and the practices best positioned to capture that advantage are those that have already invested in or are actively developing office-based laboratory or freestanding imaging center infrastructure. For practices still primarily dependent on hospital outpatient settings, the analysis is surfacing a structural vulnerability that the current rate environment is making progressively more visible.
The practical question is not whether to develop non-facility capability — the financial data argues consistently for it — but how to sequence that development given the capital requirements, credentialing timelines, and payer contract development work that non-facility program establishment requires. Practices that begin that development process in the second half of 2026, informed by the current site-of-service payment analysis, will be operational in non-facility settings in 2027–2028 rather than 2029–2030 — a meaningful lead time in a competitive market where OBL development is accelerating across multiple specialties simultaneously.
MARCA: What the Bill Does and Where It Stands
The Medical Imaging and Radiation Therapy Advancement Act — MARCA — is legislation that addresses the scope of practice and Medicare billing recognition of radiologist assistants, a mid-level imaging professional credential that has existed for over twenty years but has not been recognized as a distinct billing provider type under Medicare. Currently, radiologist assistants perform imaging procedures and fluoroscopy under radiologist supervision but cannot bill Medicare independently — their services are subsumed into the supervising radiologist’s billing. MARCA would establish Medicare recognition of radiologist assistants as a distinct provider category, allowing their services to be billed under their own NPI in defined supervision and scope-of-practice circumstances.
As of mid-2026, MARCA has been reintroduced in the current Congress with bipartisan support and has advanced through committee consideration in the Senate. The bill has not yet achieved floor votes in either chamber, and its legislative timeline remains uncertain — the pattern of prior MARCA introduction cycles has been bipartisan introduction, committee advancement, and failure to achieve floor vote in the same Congress, followed by reintroduction in the subsequent session. The mid-2026 progress is more advanced than in prior cycles, and advocacy organizations including the American Society of Radiologic Technologists and the American Registry of Radiologic Technologists are reporting increased Congressional engagement with the bill’s provisions.
For radiology practices, MARCA’s practical significance operates on two levels. The immediate workforce level: radiologist assistant recognition under Medicare would provide practices with a more financially sustainable model for deploying RAs in imaging supervision and procedure assistance roles, by creating a direct billing pathway rather than requiring their services to be absorbed into the supervising radiologist’s billing at no marginal reimbursement. The longer-term workforce level: Medicare recognition would increase the career viability of the RA credential, which affects training program enrollment, workforce pipeline development, and the long-term supply of qualified mid-level imaging professionals that radiology practices depend on as radiologist shortages persist.
Practices should monitor MARCA’s legislative progress through the ASRT and ARRT advocacy communications and through congress.gov for current bill status. If MARCA achieves enactment in the current Congress, implementation planning — including credentialing, enrollment, and billing system preparation for RA Medicare billing — would need to begin promptly after enactment to avoid delays in capturing the billing recognition the legislation would provide.
| ★ The summer 2026 strategic summary for radiology Non-facility settings are gaining ground financially in 2026, and the practices best positioned for the next three to five years are those building or expanding office-based and freestanding imaging center capabilities now. MARCA’s legislative progress bears watching — if enacted, it changes the workforce economics of radiologist assistant deployment in ways that matter for practice financial planning. Both developments reward proactive analysis rather than passive monitoring. |
Sources:
- CMS Physician Fee Schedule Final Rule CY 2026: Non-Facility and Facility RVU Values. cms.gov/medicare/physician-fee-schedule
- American College of Radiology. “2026 Site-of-Service Reimbursement Analysis: Diagnostic and Interventional Radiology.” ACR Practice Economics Resources, Summer 2026. acr.org
- Harvey L. Neiman Health Policy Institute. “Radiology Practice Site-of-Service Trends 2024–2026.” neimanhpi.org
- American Society of Radiologic Technologists. “MARCA Legislative Update: Mid-2026 Status Report.” asrt.org, 2026.
- Congress.gov. Medical Imaging and Radiation Therapy Advancement Act (MARCA). Current bill status. congress.gov
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