Medicare Imaging Bill (ROOT Act) Tightens Oversight, Tracks 'Low Compliant' Doctors Starting 2026

The Radiology Outpatient Ordering Transmission Act—or the ROOT Act—is making big changes to how Medicare tracks advanced medical imaging orders (think MRIs and CT scans). Starting January 1, 2026, the systems doctors use to check if an imaging order is appropriate will have to send detailed data directly to the Secretary of Health and Human Services (HHS).

This bill essentially upgrades Medicare’s ability to police whether doctors are following clinical guidelines when they order certain scans. Right now, doctors consult a Clinical Decision Support (CDS) mechanism, which is software that checks the order against medical criteria. Under the ROOT Act, these CDS systems must now report the details of that consultation, plus “any other data the Secretary asks for,” directly to the government. This gives HHS a much clearer, real-time look into whether imaging is being overused.

The New Compliance Scorecard

For providers, the biggest change is the introduction of a new compliance tracking system. Starting in 2026, HHS will annually identify “low compliant” ordering professionals. A doctor earns this designation if their rate of using the required CDS mechanism falls below a threshold set by the Secretary. This is the government giving doctors a report card on their ordering habits—and the consequences could be real.

For example, if you’re a doctor ordering a lot of scans, you will be under the microscope. The bill mandates that no later than 2031, and every five years after, HHS must review these compliance rates and propose new ways to enforce the rules. This could include requiring prior authorization for the scans ordered by “low compliant” doctors or adjusting their payments. This means that a doctor’s ordering habits today could directly lead to more administrative hassle or payment cuts down the road.

Administrative Headaches and Data Demands

The ROOT Act also adds administrative steps for everyone involved in a scan. If you get an advanced imaging service, the doctor who performs the scan (the radiologist or technician) must include the National Provider Identifier (NPI) of the doctor who ordered the scan on the claim form starting in 2026. This might sound like a technicality, but it’s a crucial step that links the payment directly back to the ordering doctor, making it easier for Medicare to track who is ordering what and why.

This increased data demand also hits the companies that run the CDS software. They must now maintain and report specific information directly to the Secretary, adding new regulatory costs and burdens to their operations. And that provision allowing the Secretary to ask for “any other data” is extremely broad, raising questions about how much information HHS will ultimately demand.

Exemptions for Rural Areas and Prevention

In a nod to practical realities, the bill carves out some important exemptions from the mandatory CDS consultation rule. If you are a doctor working in a small practice or a designated health professional shortage area in a rural location, you are exempt from having to consult the CDS mechanism before ordering a scan. This is a crucial break for rural providers who often have limited resources and connectivity.

Crucially for patients, certain preventive and screening services are also exempt. This includes common, necessary scans like mammograms, lung cancer CT screenings, and CT colonoscopies. If you’re getting one of these routine, life-saving scans, your doctor won't have to jump through the new CDS hoops, ensuring access to essential preventive care isn't slowed down by this new compliance framework.