CMS Implements 2026 Billing and Coding Changes

The Centers for Medicare & Medicaid Services (CMS) has rolled out significant billing and coding changes for 2026 that directly affect outpatient imaging providers. Practices must update their systems to comply with revised CPT/HCPCS codes and new reimbursement benchmarks for services like Revenue Code 0402 (“Imaging Services – Diagnostic”) to ensure proper charge capture and avoid revenue loss.

- The shift to outpatient imaging is a significant trend, with projections indicating a 14% growth in advanced outpatient imaging and 10% in standard outpatient imaging over the next decade. Approximately 40% of all radiology volume is now conducted in outpatient settings, driven by patient preference for lower costs and convenience, alongside technological advancements. - Payer and employer preferences are increasingly steering patients toward lower-cost freestanding imaging centers, a factor that, along with site-neutral payment policies, is accelerating the move of services out of traditional hospitals. Shifting just 10% of hospital-based care to outpatient facilities could result in an estimated $125 billion in annual savings for the U.S. healthcare system. - The mobile medical imaging services market is projected to grow from $17.31 billion in 2026 to $21.13 billion by 2031, reflecting a compound annual growth rate of 4.07%. Key players in this expanding market include Akumin Inc. (Alliance Healthcare Services), RadNet, Inc., and DMS Health Technologies. - Health systems are actively developing "systemness" strategies to manage and coordinate imaging services across their networks of hospitals and growing outpatient sites to capture this market shift. However, this has created pressure on private radiology groups, with some hospitals considering bringing imaging services in-house to control costs as they face requests for financial support from these groups. - Staffing remains a primary concern for radiology administrators, with a national shortage of radiologists intensifying recruitment competition. To mitigate this, imaging centers are adopting new staffing models that include imaging aides and are using AI to support less experienced technologists. - The FDA continues to authorize a rapidly growing number of AI-enabled tools for radiology, with the total number of approved devices reaching 1,039 by late 2025. Leading vendors in this space include GE Healthcare, Siemens Healthineers, and Philips. - For radiology administrators, the focus for 2026 includes navigating reimbursement challenges, addressing workforce shortages, and strategically integrating AI to improve workflow. The Certified Radiology Administrator (CRA) exam is being updated in Fall 2026 to better reflect the increased focus on applying and analyzing knowledge in real-world scenarios. - Consolidation is reshaping the competitive landscape, with large imaging groups expanding their footprint, putting pressure on independent providers to maintain operational efficiencies. This trend is expected to continue, leading to more mergers and acquisitions in the sector.

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