Due to recent momentum on physician payment reforms in Congress, a possible legislative pathway has emerged for the Radiology Outpatient Ordering Transmission (ROOT) Act, which revives and reforms the Appropriate Use Criteria (AUC) policy for advanced imaging orders. While unlikely to pass until after the midterms, the GOP and Democratic House “doc caucuses” are reportedly working on a set of comprehensive reforms to the physician fee schedule that could move in the lame duck period (the time after the mid-terms in November but before the next Congress begins in January). As usual, cost concerns could hold back the broader package, but because the ROOT Act saves money, Congress may be keen to include it as a pay-for.

What the ROOT Act Would Change

For context, the ROOT Act, which we first covered in AHRA’s July/August 2025 edition of Radiology Management, aims to correct the flaws with the original AUC policy first passed by Congress in 2014. Notably, the ROOT Act would remove the claims reporting requirements included in the original policy that had proved insurmountable for the Centers for Medicare and Medicaid Services (CMS) to implement. Instead of gathering data from every advanced imaging claim, CMS would collect data on the compliance rates of ordering professionals from the qualified clinical decision support mechanisms (qCDSM) themselves. The only requirement for furnishing professionals under the new policy would be to include the ordering professional’s national provider identifier (NPI) on claims for advanced imaging services.

While clinicians ordering advanced imaging for Medicare patients would be required to consult with AUC through a qCDSM, the result of that consultation would not impact Medicare coverage or reimbursement of the image itself. Furthermore, instead of subjecting “outlier” ordering professionals to prior authorization as the old AUC policy would have done, the ROOT Act takes a slower, softer approach. As an alternative, the legislation requires CMS to use the data from the qCDSMs to identify “low compliant” ordering professionals and issue a study (in 2031) to Congress with ideas on mechanisms for improving compliance. While assessing prior authorization would be a part of this study, Congress would need to pass further legislation to impose any requirements or policies on the low compliant ordering professionals.

A Path to Modernization

With this softer approach, the ROOT Act is more palatable to ordering professionals who had historically resisted the AUC policy. Furthermore, because the ROOT Act could generate savings to Medicare of up to $2 billion over 10 years by reducing unnecessary orders, this may help pay for the broader physician pay reforms that the whole physician community really wants. Put it all together, and you have a pathway for AUC to be reborn by the end of 2026.

On May 20, 2026, American College of Radiology (ACR) CEO Dr. Dana Smetherman made this appeal directly to Congress, writing in her testimony to the Energy and Commerce Subcommittee on Health that “The ACR acknowledges the fiscal and budgetary challenges associated with Medicare payment reform. To help offset expected costs, ACR suggests amending Section 218 [the original AUC policy] of the Protecting Access to Medicare Act of 2014 (PAMA) … The Radiology Outpatient Ordering Transmissions (ROOT) Act … would modernize the AUC program and facilitate implementation of a desperately needed utilization management tool for the ordering of advanced diagnostic imaging services.”

Yet Unknown: The CBO Score

Despite this promising momentum, the official arbiter of legislative costs/savings, the Congressional Budget Office (CBO), has not yet analyzed the ROOT Act. If the CBO officially scores the legislation as generating savings, that will give the bill and broader physician pay package a huge lift. Conversely, if the CBO estimates that the savings are minimal, that will dampen the odds that Congress moves forward with this AUC reform.

What This Means for Imaging Leaders

For many years, AUC implementation was the top regulatory issue for AHRA and the broader medical imaging management community. AHRA has always supported the broader goals of improving the quality of imaging orders, but the original policy would have required the technical component of imaging to properly transfer data from the ordering professional to Medicare on claims forms and put our reimbursement at risk if those data elements were not complete.

Thankfully, the ROOT Act removes this liability for furnishing providers by requiring qCDSMs to transfer information about the quality of advanced imaging orders directly to CMS, removing our role in that data transfer. Therefore, if you see a headline later this year that AUC is back, know that its second version is much better than its first.