Payment Policies, New Codes, and Rising Costs: Preparing for Radiology’s 2026 Storm of Challenges with Subject Matter Expert Laura Manser

A storm of coding and compliance changes will sweep through interventional radiology and radiology, creating challenges for coding and compliance professionals alike. Reimbursement is especially at risk with the new lower extremity revascularization code set taking effect at the start of the new year. With so many factors at stake in 2026, expert guidance is imperative to navigate the surging tides of change. Nationally renowned radiology, interventional radiology, and nuclear medicine subject matter expert Laura Manser, CPC, CPCO, CDEO, CPMA, CEMC, CIRCC, RCC, delivers professional insight into the changes that will transform the new year in part one of our exclusive interview series. With an expert spotlight on these challenges, professionals won’t be left in the dark and can better prepare for any problems that may surface.

Question:

For 2026, why is the conversion factor considered a deceptive increase in terms of overall payment boost? What should people know about the conversion factor and other payment policies?

Answer:

“The 2026 conversion factor looks like good news at first glance. Yes, we’re seeing the first increase in six years, with the rate going up to $33.5675 for APM participants and $33.4009 for non-participants. But that headline number doesn’t tell the real story.

The problem is that any upward movement in the conversion factor gets quickly offset by other CMS adjustments happening at the same time. The big one is the 2.5% efficiency adjustment that CMS finalized. They’re reducing work RVUs across the board for non-time-based codes, which includes most radiology services. CMS’s own estimates show diagnostic radiology taking a 2% hit overall, nuclear medicine down 1%, and radiation oncology down 1%. Only interventional radiology sees a positive 2% impact.

Then there’s the site-of-service payment differential. CMS reduced indirect practice expense RVUs by 50% for services performed in hospital settings. Diagnostic radiology got an exemption, but interventional radiology did not, which will significantly impact those practices.

Beyond these specific changes, you’ve got the usual suspects: budget neutrality rules, valuation shifts, and efficiency assumptions that redistribute dollars across specialties. In radiology, those redistributions tend to work against us.

When you add it all up, that conversion factor increase is essentially being clawed back through these other mechanisms. A 1% increase can easily be neutralized or even reversed once all the underlying adjustments are applied. This is why practices need to stop chasing the headline number and start reading between the lines. The conversion factor is just one component of the process, not a solution.

Financial clarity comes from doing a code-level analysis to understand your specific impact, rather than celebrating a number that doesn’t translate into actual increased payments. What matters is how relative value changes and payment policies interact in your particular practice setting.”

Question:

The ~2.5% efficiency cut will lower work Relative Value Units (wRVUs) for many services. How would you explain the impact of this change to stakeholders concerned about reimbursement?

Answer:

“This is really frustrating because CMS’s reasoning is fundamentally flawed when it comes to radiology. Their argument is that services become more efficient over time due to technology and improved workflows, so they should be paid less. But the opposite is actually true in our field.

Take CT scans as a perfect example. Twenty years ago, a CT study might have 40 images. Today, that same study routinely has 400 or more images—ten times the data a radiologist needs to review and interpret. How is that more efficient?

And then there’s AI. CMS assumes technology makes us faster, but right now AI tools are flagging additional findings that require more physician review, correlation with other studies, and documentation. It’s adding complexity, not reducing it. The reality in radiology and IR is that most groups have already optimized every inch of their process. There’s not much efficiency left to gain.

The practical impact is about a 1% overall reduction in reimbursement when you factor everything together. That might not sound like much, but in an environment where practice expenses keep rising, workforce shortages are real, and we’re already operating on thin margins, every percentage point matters.

For physicians, this feels personal because it touches compensation, productivity, and perception of workload. When talking to them about this, it’s important to remind them that wRVUs are a measurement tool, not an overall verdict on value. The key is to run side-by-side comparisons of your top codes under the 2025 and 2026 models to quantify the impact and plan ahead. Then, have the compensation conversation early. Waiting until Q1 to feel it in paychecks creates frustration. Data gives everyone a shared starting point.

The really concerning part is that CMS plans to apply this efficiency adjustment every three years going forward. The Radiology Business Management Association (RBMA) is gathering data to show CMS the reality of increased complexity in radiology, and we’re going to need practices to help document this with real-world examples and metrics. Without pushback supported by hard data, this will continue to erode reimbursement year after year.”

Question:

How should professionals best prepare for the changes?

Answer:

“Regarding the efficiency adjustment, practices need to start collecting real-world data now to counter CMS’s flawed assumptions. Document actual interpretation times, track image volumes per study, and measure how AI tools are adding to workflow rather than reducing it. RBMA will be gathering this data to present to CMS, and member participation will be critical to building a case for reversing this policy before the next three-year cycle.

On the practice expense issue, be prepared to provide detailed cost information if RBMA or other organizations request it. Share your actual indirect cost data, demonstrate how current reimbursement falls short, and help build the evidence base showing that radiology’s costs have changed dramatically since 2006. The only way to fix this long-standing problem is with concrete data from actual practices showing what it really costs to deliver radiology services today.”

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