On March 28, 2019, Rep. Mike Doyle introduced H.R.1970, the Medicare Access to Radiology Care Act of 2019 (MARCA) not to be confused with MACRA, the Medicare Access and CHIP Reauthorization Act that instituted the Quality Payment Program. MARCA aims to ensure Medicare payment for non-diagnostic services performed in hospital and office settings by radiologist assistants (RA) and radiology practitioner assistants (RPA). The MARCA bill proposes a less restrictive version of the “incident to” rules in that not all requirements need to be met in the office setting for non-diagnostic services to be billed.

This proposed bill comes on the heels of the CY 2019 Medicare Physician Fee Schedule (MPFS) Final Rule which permits RA’s and RPA’s to perform diagnostic tests, to the extent permitted by state law and scope of practice, under direct supervision (physician must be present in the facility and immediately available if necessary) of the radiologist, rather than the previously required personal supervision (physician present in the room when service is being performed). Examples of diagnostic tests are fluoroscopy procedures such as barium swallow, UGI, BE, ERCP, cystography, and VCUG. This rule fell short of providing consistent supervisory requirements and reimbursement for RA’s and RPA’s regardless of the site of service.

Note that the CY 2019 MPFS supervision rules only pertain to diagnostic tests (70000 series codes) in the hospital outpatient setting, IDTFs, and physician offices. In regard to non-diagnostic services, current regulations require the physician to perform in order to be paid in the hospital setting.

MARCA legislation is designed to address this gap and would allow Medicare coverage for non-diagnostic services, what we interpret to mean minor interventional procedures, as well as diagnostic tests representing the work RA’s and RPA’s are trained to perform, regardless of the site of service, when performed under direct supervision. The grids below provide a comparison of supervision requirements under the current rule vs. MARCA.

The proposed legislation already has bipartisan support within the House as well as support from the American Society of Radiologic Technologists (ASRT), American Registry of Radiologic Technologists (ARRT), American College of Radiology (ACR), and Society of Radiology Physician Extenders (SRPE).

As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.


Lauren Sloan, MHA, RD, LD

Director of Regulatory Affairs