The New X-Ray Differential Payment Policy in Effect


The Consolidated Appropriations Act of 2016 included a new public health policy designed to push providers to adopt digital X-ray technology - in short, to convert film and cassette-based (CR) radiography systems to fully digital units, which the California Podiatric Medical Association (CPMA) reported on in May of 2016.

On January 1, 2017, CMS (and other payors) began imposing a 20% reimbursement penalty to the Medicare technical component for X-ray procedures performed on film-based systems. Beginning in January 2018, users of CR-based units will likewise feel the reimbursement pinch, as CMS imposes a 7% penalty to the Medicare technical component of X-ray procedures performed using CR systems. That reduction is scheduled to increase to 10% in January 2023.

Providers should perform the following three steps to help mitigate payment penalties:

  • Inventory your assets for X-ray exams that are billed under fee-for-service (FFS) Medicare and identify your analog equipment.
  • Assess the volume of X-ray procedures performed on noncompliant equipment to calculate the financial impact to your institution.
  • Develop and execute an asset plan that converts your noncompliant X-ray systems to digital.