CMS Requests Information on Duplicate Imaging: What Radiology Practices Should Prepare For

What Is the CMS Duplicate Imaging RFI?

As of July 2026, the CMS CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) includes a Request for Information targeting duplicate imaging exams and laboratory testing. CMS is soliciting public input on the scope and frequency of repeat or duplicate diagnostic imaging studies billed to Medicare, signaling that new utilization management requirements, prior authorization expansions, or payment policy changes for repeat imaging may follow in a future rulemaking cycle.

• What this is: An RFI is a formal data-gathering step, not a proposed rule. CMS is asking for information before deciding whether to act, which means no new requirements are in effect today.
• Why it matters now: Every CMS RFI on a specific billing pattern has historically preceded a policy change. Radiology practices that bill repeat imaging studies should begin auditing their patterns before any new rules are proposed.
• Comment deadline: The CMS-1848-P comment period, which includes the RFI, closes September 14, 2026. Radiology groups and imaging centers can submit data and feedback at regulations.gov under docket CMS-1848-P.

What CMS Is Asking About Duplicate Imaging

The RFI on duplicate imaging appears inside the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), published in the Federal Register on July 16, 2026. CMS is requesting information specifically about the prevalence of duplicate or repeat diagnostic imaging exams and laboratory tests billed to Medicare, with particular attention to cases where the same or similar study is performed on the same patient within a short timeframe by the same or different providers.

CMS is not proposing a specific rule change in this RFI. Instead, the agency is asking providers, billing companies, payers, and other stakeholders to share data on how often duplicate imaging occurs, what clinical scenarios justify it, and what mechanisms could reduce unnecessary repetition without blocking clinically appropriate repeat studies. This is the standard CMS playbook for building the evidentiary record that supports a future proposed rule.

For radiology practices, the RFI carries weight because imaging is one of the highest-cost categories in Medicare Part B, and duplicate imaging has been flagged by the OIG in prior audits and work plan items as an area of potential waste. The Radiology Patient Action Network noted that CMS is specifically targeting duplicate imaging exams alongside laboratory testing, which suggests the agency views both categories as having measurable waste that could be addressed through payment or utilization policy.

Does This Affect My Radiology Practice?

The RFI itself does not create any new requirements. But the practices that should pay the closest attention are those that routinely perform or bill repeat imaging studies on the same patient within short intervals. This includes emergency radiology groups where patients return within days or weeks, imaging centers that receive referrals from multiple ordering physicians who may not know a study was already performed elsewhere, and interventional radiology practices that order pre-procedure and post-procedure imaging on the same patient in a compressed timeframe.

In our experience matching radiology practices with billing companies, the practices that face the highest audit risk on duplicate imaging are those with no automated check in their scheduling or billing workflow that flags when the same study was recently performed on the same patient. Without that check, the practice has no visibility into whether a repeat study will trigger a payer review, an NCCI edit denial, or a future CMS utilization policy.

If CMS eventually proposes a policy based on this RFI, the most likely forms would be prior authorization requirements for repeat imaging above a frequency threshold, payment reductions on the second study within a defined window, or documentation requirements proving that the repeat study was clinically necessary and not duplicative. Radiology practices that can already demonstrate clinical justification for every repeat study will be positioned to comply. Practices that cannot will need to build that capability. For broader context on how the 2027 proposed rule affects radiology reimbursement overall, see our radiology reimbursement 2027 guide.

Common Duplicate Imaging Scenarios and Risk Level

Not all repeat imaging is duplicative. Some is clinically appropriate and defensible. Understanding the distinction is what protects a practice when CMS converts this RFI into a policy. Here are the scenarios that appear most frequently in radiology billing data:

The high-risk scenarios are the ones CMS is most likely targeting. A radiology practice that performs the same study on the same patient within a short window without documented clinical change or a protocol-driven reason is the billing pattern this RFI was designed to surface.

How to Prepare for New Duplicate Imaging Policies

Even though no new requirements exist today, the following steps position your practice to comply with whatever CMS proposes based on this RFI.

1. Audit your repeat imaging volume. Pull a report of all imaging studies where the same CPT code was billed for the same patient within 30 days. Identify how many were clinically justified versus potentially duplicative.
2. Document clinical justification for every repeat study. Ensure the ordering provider’s documentation includes the specific clinical reason the repeat study was necessary. A note that says “repeat CT for monitoring” is not sufficient. The note must state what changed or what clinical question the repeat study answers.
3. Build a scheduling flag for repeat studies. Configure your scheduling or RIS system to alert staff when the same study is being scheduled for a patient who had that study within the last 30 days. The flag does not prevent the study. It prompts documentation.
4. Review ACR Appropriateness Criteria for your most-billed repeat studies. The ACR guidelines provide evidence-based criteria for when repeat imaging is appropriate. Practices that align their documentation with ACR criteria have the strongest defense against future utilization reviews.
5. Submit a comment to CMS by September 14. If your practice has data on how often repeat imaging is clinically necessary and why, include it in your comment. CMS is asking for exactly this type of operational data, and radiology groups that provide it influence how the eventual policy is designed.
6. Confirm your billing company tracks CMS RFIs. Across the billing companies we vet, the ones that protect radiology revenue most effectively are the ones monitoring CMS policy signals before they become rules. If your billing partner has not mentioned this RFI to you, ask whether they are tracking it and whether they have a plan for when it becomes a proposed rule.

Mistakes That Increase Audit Exposure

Providers often come to us after a payer audit has already targeted their repeat imaging patterns, and the same set of preventable errors appears every time.

The most common mistake is performing a repeat study without checking whether the patient already had that study at another facility. When a referring physician orders an MRI that the patient already had at an ER three days ago, and your practice performs it without verifying prior imaging, the claim for the second study is the one that triggers a duplicate review. The fix is a simple intake step: ask whether the patient has had this study recently, and request prior imaging records before proceeding.

The second mistake is documenting repeat studies the same way as initial studies. A repeat CT of the chest that uses the same templated indication as the original study gives the payer no reason to believe the second study was clinically necessary. The documentation must specify what changed between the first and second study, what new clinical question is being answered, or what guideline-based protocol requires the repeat interval.

The third mistake is ignoring payer-specific frequency limits. Several commercial payers and Medicare Advantage plans already enforce frequency limits on imaging studies, particularly for MRI of the spine and PET scans. A practice that does not track which payers apply frequency limits and what those limits are will generate preventable denials that a billing company with radiology expertise would catch at the pre-submission stage.

Frequently Asked Questions

Next Steps

Start by running a repeat imaging audit on your Medicare claims from the last 12 months to quantify how often the same study was billed for the same patient within 30 days.

For the full picture of how the CY 2027 proposed rule affects radiology payment and quality reporting beyond duplicate imaging, see our 2027 radiology reimbursement guide.

If your billing team does not currently flag repeat studies or track payer frequency limits, a radiology billing company with imaging-specific compliance workflows can close that gap before CMS converts this RFI into a rule.