New ROOT Act Ties Doctor Payments to Digital Checklists, Starting January 2026

The Radiology Outpatient Ordering Transmission (ROOT) Act is all about making sure doctors use digital tools when ordering certain medical scans—and starting January 1, 2026, it’s putting teeth behind that requirement. Essentially, this bill updates existing rules to make compliance mandatory for payment. If a doctor orders a specific imaging service, the claim for that service won't get paid unless it proves a qualified clinical decision support mechanism (that's the fancy name for the software that checks if the scan is medically necessary) was consulted first.

The Digital Gatekeeper: What Changes in 2026

Think of this as a new, high-stakes digital checkpoint for ordering medical scans. Currently, these decision support tools are encouraged, but the ROOT Act makes them the official gatekeeper for payment. For the busy professional, this means less chance of getting an unnecessary or inappropriate scan, which sounds great. But for the healthcare provider, the administrative load just went up. Not only must the ordering doctor consult the tool, but the professional performing the imaging service (like the radiologist) must include the ordering doctor’s National Provider Identifier (NPI) right on the claim form. This ensures every step is tracked, making payment conditional on perfect documentation. If the system glitches, or the paperwork is wrong, the provider risks not getting paid.

Who Gets a Pass on the Digital Checklist?

The bill understands that not everyone has the same resources, which is a key win for access in certain areas. Starting in 2026, the mandatory consultation rule won't apply if the service is part of a clinical trial, or if the ordering doctor practices in a small practice or a designated health professional shortage area located in a rural area. This is a crucial exemption: it protects access to care in places where doctors might be juggling multiple roles and lack the deep administrative support of a large hospital system. The bill also specifically exempts common screening procedures like mammograms and lung cancer screenings, which makes sense since their medical necessity is already established.

The New Compliance Scorecard

Before, the system tracked "outlier" doctors—those who ordered scans without using the tools too often. The ROOT Act changes the terminology to "low compliant" ordering professionals, effective January 1, 2026. The Secretary of Health and Human Services (HHS) will set a specific percentage threshold, and if a doctor’s rate of consulting the decision tool falls below that, they are flagged as "low compliant." This is where the rubber meets the road: HHS gets the power to set the bar for compliance. To calculate this rate, the government will rely on the data that the decision support mechanisms themselves are now required to report directly to HHS.

What This Means Down the Road

The most interesting—and potentially concerning—provision is what happens after doctors are flagged. The bill mandates that by 2031, and every five years after, the Secretary must report to Congress on how well doctors are complying and suggest ways to improve the system. These suggestions can include requiring prior authorization for imaging ordered by low compliant professionals. While this is currently just a suggestion for a future report, it signals that the ultimate goal is to put up more administrative hurdles—like pre-approvals—for doctors who don't toe the line. For patients, this could mean more time waiting for a necessary scan if their doctor is deemed “low compliant,” adding friction to an already complex healthcare system. The ROOT Act trades administrative simplicity for increased oversight, placing a high premium on precise digital documentation for every scan ordered.