Working to Modernize the Medicare Conditions of Portable X-Rays

Modernizing Medicare Requirements for Portable X-ray Services Most provisions related to Medicare coverage of portable x-ray services have not been updated for more than 40 years.

APDA recognizes that the conditions of coverage for portable x-rays have not been updated in more than 40 years.  These regulations are out-of-date and force our Members:

  • To get physician signatures on orders when other radiology orders in non-portable setting do not require them.
  • To obtain chart notes from long-term facilities confirming the order for the PXR, that the x-ray was used in the evaluation and management of the patient and that a portable exam was medically necessary.

With goal of modernizing these out-of-date regulations and relieving our members of some of these burdens, APDA has formulated a Legislative Ask, which it has presented to Members of Congress.  We have incorporated the “Ask” into a letter requesting support from SNF Medical Directors and Directors of Nursing.  Please see both letter and our Legislative request below.

APDA's lobbying firm, Dumbarton & Associates, is optimistic that the new Congress, when it convenes in January 2017, will be able to incorporate our “Ask” into one of the many pending health care bills.  In the meantime, you can do your part by sending our legislative request to the Medical Directors and DONs at your facilities.  You should supply them with the name and address of your Senator or Congressman.  If they sign the letter and return it to you, APDA will make sure the letter is delivered to your state's Congressional members.


 E-mail Template for Sending Request to your Senators

Dear Senator  ________________ :


As a medical director providing care for nursing home residents in (your city and state), I am seeking your support for legislative provisions to modernize Medicare requirements for portable x-ray services. This change is needed to allow me to provide quality care in an efficient manner to the frail, elderly residents of nursing homes.


Most provisions related to Medicare coverage of portable x-ray services have not been updated for more than 40 years.  It is important that Congress act to update the conditions of coverage for portable x-ray services under Medicare so they conform with subsequent Medicare policy and guidance and contemporary practices in health care delivery.  The provisions that must be updated are in the Social Security Act, 42 CFR, Part 486, Subpart C Subpart C— Conditions for Coverage: Portable X-Ray Services.


The attached legislative provisions address three areas that need to be updated:

  • Access for SNF and NF Beneficiaries
    • Medicare beneficiaries in skilled nursing facilities and nursing facilities must be considered reasonable and necessary for portable x-ray services when ordered by a qualified practitioner. 
    • This update maintains the authority of the ordering practitioner to determine the need for a portable x-ray, protects program integrity, and provides beneficiaries with the services they need in the appropriate service location.
  • Orders and Documentation
    • The legislative language allows the supplier's supervising physician to specify, including through the use of standing protocols, the areas of the body to be exposed, the number of radiographs to be obtained and the views needed that are consistent with the order for the test.
    • This update will allow supervising physicians to direct the performance of the exams while preserving the ordering practitioner's authority to include in the order the radiologic examination to be performed, the areas of the body to be exposed, the number of radiographs to be obtained, and the views needed.
    • The legislative language also eliminates the signed, written order requirement, which makes portable x-ray consistent with all other diagnostics under Medicare.
  • Qualified Technologists
    • Qualified technologists should include those that successfully passed an examination given by the American Registry of Radiologic Technologists (ARRT) in the specialty of general radiography and maintain certification.
    • This update reflects the ARRT credential option that did not exist when the portable x-ray technologist requirements were written.


My specific request is that you consider support of the legislative language to update these three areas. These provisions should be included in the health reform legislation the Senate is considering. 


Thank you for considering my specific request. I will follow up with your office to determine if you will be able to take action to address this issue.





Legislative Language

We respectfully request your support for the inclusion of the following updates: 


Section 1832 of the Social Security Act, [42 U.S.C. § 1395k], is amended by adding the following new subsection (c):


(c)  Notwithstanding any other provision of this Act, transportation, set-up and related services associated with the portable delivery of a diagnostic x-ray test furnished by a supplier that meets the qualifications established by the Secretary for furnishing portable x-ray services under 42 C.F.R., Part 486, Subpart C may be ordered by a physician or non-physician practitioner as provided under 42 C.F.R., §410.32(a)(2). Such order shall specify the reason an X-ray test is required, and either (i) the order shall specify the radiologic examination to be performed the areas of the body to be exposed, the number of radiographs to be obtained and the views needed or (ii) the supplier's supervising physician may specify, including through the use of standing protocols, the areas of the body to be exposed, the number of radiographs to be obtained and the views needed that are consistent with the order for the test. Without limiting any other coverage otherwise established under this Act, such transportation, set-up and related services associated with the portable delivery of a diagnostic x-ray test shall be considered reasonable and necessary for the diagnosis or treatment of illness or injury if any such x-ray diagnostic test is furnished in a skilled nursing facility as defined in § 1819(a) of Title XVIII [42 U.S.C. § 1395i-3(a)] or in a nursing facility, as defined in § 1919(a) of Title XIX [42 U.S.C. § 1396r(a)].



Section 1861(s)(3) is amended as follows:

 “diagnostic X-ray tests (including tests under the supervision of a physician [LICENSED IN EITHER THE JURISDICTION WHERE THE SUPPLIER'S PRINCIPAL OFFICE IS LOCATED OR WHERE THE TEST IS PERFORMED] , furnished in a place of residence used as the patient's home, if the performance of such tests meets such conditions relating to health and safety as the Secretary may find necessary and including diagnostic mammography if conducted by a facility that has a certificate (or provisional certificate) issued under section 354 of the Public Health Service Act), diagnostic laboratory tests, and other diagnostic tests; provided, however, the conditions imposed by the Secretary shall in addition to those established under 42 C.F.R, Part 486, Subpart C permit tests covered by this definition to be performed by individuals who have successfully passed an examination given by the American Registry of Radiologic Technologists (ARRT) in the specialty of general radiography and maintains certification from ARRT by completing continuing education requirements.


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