Proposed 2026 Medicare allowances for portable x-ray transportation codes

Introduction

The A/B Medicare administrative contractors (MACs) recently completed a preliminary evaluation of data submitted through the portable x-ray (PXR) survey. The PXR survey was designed to capture cost and utilization details from suppliers across all jurisdictions and ensure accurate and equitable reimbursement methodologies for transportation of portable x-ray equipment. The survey responses inform MAC allowances and represent the first phase of review and will inform the next steps in refining payment allowances. 

View preliminary allowances

Methodology

To ensure consistency and transparency, the MACs applied the following methodology to evaluate all survey responses.

1. Establishing Relative Value Units (RVUs):
   Survey cost inputs were normalized and translated into RVUs, providing a standardized way to compare data across suppliers.
2. Applying Local Geographic Practice Cost Indices (GPCIs):
   When supplier data was sufficiently detailed, local GPCIs were factored into the calculations to reflect regional variations in operating costs.
3. Use of the Ambulance Inflation Factor (AIF) for 2026:
   In cases where the survey participation was limited or responses insufficient to generate reliable values, the previous allowance was adjusted using the Inflation Factor (AIF) for 2026 to ensure continuity of pricing. This preserves consistency across all MAC jurisdictions.
4. Validation and review:
   Each MAC is responsible for validating supplier-submitted data, including cost components and utilization assumptions, before and after integration into the pricing model.

This layered approach balances supplier-provided survey data with standardized national practices, ensuring that reimbursement rates are fair, consistent, and aligned with Medicare program requirements.

Excluded line items

Specific line items were excluded from the preliminary results because they are already accounted for within the practice expense (PE) component of the diagnostic test itself.

Excluded as overhead costs

• Credit card fees
• Donations
• Employee inducements (sign-on bonus, retention bonus, appreciation bonus, recognition bonus, 401k match)
• Executive management costs (salaries, bonuses, vehicles)
• Fleet management
• Legal penalties
• Medical director/physician supervisor costs (salary, bonuses, fees)
• Shredding services
• Traffic violations/tickets

Excluded as already included in x-ray procedural costs

• Radiation monitoring / x-ray dosimetry
• Radiology interpretations
• Supplies utilized in x-ray procedure (e.g. PPE, barium products)
• X-ray equipment costs and depreciation

Excluded when context not provided

• Bank fees
• Billing service
• Contract labor
• Dues
• Interest
• Office equipment depreciation
• Office equipment property tax
• Subscriptions
• Travel / meals

Partially excluded (some cost allowed)

• Billing service
• Customer service payroll
• Marketing costs
• Sales payroll

Excluding these items avoids duplication in reimbursement and ensures consistency with Medicare’s pricing methodology, which captures overhead and general practice costs within the PE calculation of the diagnostic test code rather than within the transportation allowance.

Next steps

The Proposed 2026 Medicare Allowances for Portable X-Ray Transportation Codes are out for comment until 10/30/2025. Suppliers will be provided with a 30-day comment period to submit clarifications to MAC email Pricing@guidewellsource.com or additional supporting information related to their previously submitted surveys or request a brief meeting. This opportunity allows suppliers to:

• Correct any errors or omissions in their survey responses.
• Provide documentation to support reported costs or utilization.
• Clarify unique circumstances that may have affected their submissions.

It is important to note that this comment period is not a resubmission window. Suppliers may only provide clarifications or additional support for data already submitted; entirely new surveys or additional line items will not be accepted.

MACs will review all feedback received during this comment period and the final allowances will be posted prior to their effective date of January 1, 2026. While supplier input will be carefully considered and may inform adjustments, it does not guarantee changes to the preliminary results. Any revisions must be consistent with CMS regulations, established methodologies, and national payment policy.

Following the review of comments, MACs will finalize validations, refine allowances where appropriate, and publish their final fees for notice. 

Disclaimer

The methodology and exclusions described in this article are consistent with CMS regulations and guidance governing Medicare payment policy. Specifically:

• 42 CFR §414.22 outlines the methodology for establishing practice expense relative value units, including the incorporation of overhead and indirect costs into the PE component.
• Social Security Act §1848(c)(2)(C)(ii) requires that PE RVUs reflect the direct and indirect practice costs associated with furnishing a service.
• Each MAC is required to validate supplier survey submissions in accordance with these authorities to ensure accuracy, avoid duplication, and maintain compliance with national payment policy.