Just as summer is about to officially begin, stakeholders in the radiology space are keeping their “fingers crossed” that the Centers for Medicare and Medicaid Services will have good news in the soon-to-be released proposed 2026 Medicare Physician Fee Schedule Rule. 

One primary focus is whether CMS will propose to extend or make permanent the ability for Level 2 tests like CT and MRI with contrast to be supervised by a physician – or non-physician practitioner if state law permits – by being virtually present and immediately available via real-time audio and video communications technology. Virtual supervision is currently scheduled to sunset on December 31, 2025. 

The publication, Radiology Business, reports that - in separate letters - the Radiology Business Management Association (RBMA) and the American College of Radiology (ACR) recently asked top HHS officials to continue allowing remote supervision in 2026 and beyond. Kudos to both organizations for keeping attention on this important health care policy decision that CMS will be making.

Given the excellent record of safety and efficacy of virtual supervision to date, one hopes that when we see the proposed rule in the coming weeks, CMS will have acted to assure the ability to continue utilizing the virtual model of supervising CT and MRI studies when contrast media is administered as part of those studies. If that does not happen, one can expect access to these studies will be dramatically harmed.