Radiology Outpatient Ordering Transmission (ROOT) Act
- Sponsor
- Sen. Blackburn, Marsha [R-TN]
- Committees
- Finance Committee (primary)
- Last action
- May 8, 2025
Bottom line
The ROOT Act streamlines data collection for Medicare imaging services by shifting reporting burdens to technology systems and exempting specific providers and services, aiming to improve compliance and reduce administrative overhead.
What it actually does
This bill, the "Radiology Outpatient Ordering Transmission (ROOT) Act," modifies Medicare's Appropriate Use Criteria (AUC) program for advanced diagnostic imaging services. It shifts the responsibility for reporting AUC consultation data from the furnishing professional (e.g., radiologist) to the qualified clinical decision support mechanism (CDSM) itself, which will report directly to the Secretary of Health and Human Services. It also introduces new exemptions for certain services and practices, redefines "outlier" ordering professionals as "low compliant," and requires furnishing professionals to include the ordering professional's NPI on claims.
Proponents argue
Supporters argue that the current AUC reporting requirements place an undue administrative burden on furnishing professionals, leading to payment delays and inefficiencies. By shifting the reporting responsibility to the CDSMs, the bill will streamline the process, improve data accuracy, and allow healthcare providers to focus more on patient care. The new exemptions for small, rural, and preventive services will also reduce burdens where the program's benefits may be less pronounced or where access to care is already a concern.
Opponents contend
Critics might argue that shifting reporting responsibility away from the furnishing professional could reduce accountability or create new challenges in data integration and oversight for the Secretary. While exemptions may reduce burden, they could also create loopholes or reduce the overall effectiveness of the AUC program in promoting appropriate imaging utilization, potentially leading to increased unnecessary imaging in exempted categories.
The bill is concise and can be read quickly, allowing for a good understanding of its proposed changes within a short timeframe.
Section 2(a)(1) and (2)(B)
Direct Reporting by Clinical Decision Support Mechanisms (CDSMs)
Currently, when a doctor orders an advanced imaging service for a Medicare patient, the facility performing the scan (the "furnishing professional") must include information on the claim confirming that the ordering doctor consulted an Appropriate Use Criteria (AUC) system. This bill changes that. Starting January 1, 2026, the AUC system itself (called a "qualified clinical decision support mechanism" or CDSM) will be responsible for directly reporting this consultation information to the Secretary of Health and Human Services, rather than it being included on the claim by the furnishing professional.
Supporters argue
Supporters argue this change will significantly reduce the administrative burden on furnishing professionals, who often struggle to obtain and correctly include the AUC consultation information on claims. This streamlines the billing process, reduces claim denials, and allows these professionals to focus more on patient care.
Critics contend
Critics might express concern that removing the reporting requirement from the furnishing professional's claim could reduce a layer of verification or accountability, potentially making it harder to track individual instances of non-compliance if the CDSM reporting mechanism faces issues.
Tradeoffs
The bill balances the goal of reducing administrative burden on healthcare providers against the need for robust data collection and program oversight. Shifting responsibility to CDSMs aims to improve efficiency but requires reliable data transmission from these third-party systems.
Section 2(a)(2)(C)
Expanded Exemptions for Specific Services and Practices
The bill adds several new categories of imaging services and ordering professionals that will be exempt from the Appropriate Use Criteria (AUC) consultation requirements. These include imaging services ordered as part of a clinical trial, services ordered by professionals in small practices (15 or fewer) or those in rural health professional shortage areas, and specific preventive or screening services like mammography, CT lung cancer screenings, and CT colonographies.
Section 2(a)(3) and (4)
Redefining and Monitoring "Low Compliant" Ordering Professionals
The bill changes the terminology from identifying "outlier" ordering professionals (those who frequently don't consult AUC) to "low compliant" ordering professionals. Starting January 1, 2026, the Secretary will annually determine a compliance rate for each ordering professional based on data reported by CDSMs. Professionals whose compliance rate falls below a certain threshold set by the Secretary will be designated as "low compliant." The bill also mandates regular studies and reports to Congress on these compliance rates and potential mechanisms to improve compliance, including prior authorization or payment adjustments for low compliant professionals.
Beginning January 1, 2026, the professional furnishing the imaging service (e.g., the radiologist or imaging center) must include the National Provider Identifier (NPI) of the ordering professional on the claim for the service, if the ordering professional is different from the furnishing professional.
Section 2(a)(2)(E)
Why it matters:This is standard legislative practice to add related but distinct requirements within the same section of law being amended. It's not necessarily evasive, but it's a detail that could be missed.
Case for: Proponents would argue this NPI requirement is essential for CMS to accurately link imaging services to the ordering professional, especially now that AUC consultation data is reported separately by CDSMs. This ensures CMS can still track ordering patterns and calculate compliance rates effectively.
Case against: Critics might argue this adds a new administrative data element to claims for furnishing professionals, even as other reporting burdens are reduced. It requires systems to ensure the correct NPI is captured and transmitted, potentially leading to new claim rejection reasons if not implemented smoothly.
Estimated impact: This will have a moderate administrative impact on furnishing professionals and their billing systems, requiring an update to ensure the ordering professional's NPI is consistently included on claims for applicable imaging services.