2026 Part B portable x-ray reimbursement rates - response to comments

Introduction

The A/B Medicare Administrative Contractors (MACs) completed their review of all supplier comments submitted in response to the preliminary 2026 Portable X-Ray (PXR) transportation allowances. This article provides clarification on key themes raised by suppliers, including the rationale for excluding certain line items, the basis for determining survey validity, and the methodology used when insufficient data were available within a jurisdiction.

The PXR survey was developed to collect standardized cost inputs from suppliers nationwide, ensuring that Medicare reimbursement for R0070 and R0075 remains accurate, equitable, and fully aligned with federal payment policy.

Clarification on Excluded Cost Categories

1. Costs Already Accounted for in the Diagnostic X-Ray Procedure
Under Social Security Act §1848(c)(1)(B) and §1848(c)(2)(C)(ii) and 42 CFR §414.22, Medicare’s practice expense RVUs must reflect the relative practice expense (PE) resources required to furnish the diagnostic x-ray service. These resources already include clinical labor, equipment depreciation, supplies, dosimetry, and interpretation-related expenses. Because these categories are already incorporated into the PE RVUs for the diagnostic test itself, they cannot also be reimbursed in the transportation allowance.

2. General Overhead Not Attributable to Transportation
Medicare requires that indirect business overhead be accounted for through the PE component of the diagnostic service, not the transportation code. Therefore, general overhead costs not directly supporting transportation were excluded, including executive salaries, corporate administrative costs, inducements, penalties, bank fees, office depreciation, which is unrelated to transportation labor or mileage.

3. Items Excluded Due to Insufficient Context
Some line items lacked the necessary detail to validate their relevance to transportation or did not include an adequate allocation methodology. Examples include contract labor without role descriptions, travel or meals without a transportation nexus, and billing or scheduling costs without support showing a direct relationship to transportation activities.

Survey Validity: Why Response Count Was Used Instead of Claim Volume
Survey reliability is based on the quality and completeness of survey response - not claim volume. High claim volume does not guarantee representative, complete, or internally consistent cost data. Weighting results by claim volume could distort cost inputs and conflict with Medicare’s requirement that payment reflect resource use rather than supplier size. Using response count ensures equal consideration and avoids disproportionate influence by high‑volume suppliers.

Rationale for Applying the AIF Uniformly Across All States Within a Jurisdiction
Where any state within a jurisdiction lacked sufficient validated responses to produce reliable cost values, MACs applied the 2026 Ambulance Inflation Factor (AIF) uniformly across all jurisdictions. This ensures consistent reimbursement within the jurisdiction, prevents fragmented methodologies, and supports suppliers who operate across multiple states. Consistency aligns with Medicare’s long‑standing principle of applying uniform payment methodologies within each MAC region.

Conclusion and Next Steps

While supplier feedback is valuable, final allowances must remain consistent with SSA §1848(c)(1)(B), §1848(c)(2)(C)(ii), and 42 CFR §414.22. MACs may incorporate clarifications supported by original submissions but cannot accept added cost categories or new data outside the comment period. Final 2026 allowances will be posted before January 1, 2026.

The Final 2026 Medicare Allowances for Portable X-Ray Transportation Codes effective on January 1, 2026, are found here.