The pillar of this revision for radiology is a structural response to the shortage of diagnostic radiologists.
The facility criteria for the imaging management add-on, long premised on in-house interpretation, were revised so that up to 20% of interpretation may be outsourced to another insured institution under defined conditions. For hospitals unable to secure diagnostic radiologists, this changes a situation that previously offered only two options: give up the add-on entirely, or keep pushing.
1. What changed
| Item | Change | Old → New | Impact |
|---|---|---|---|
| Imaging management add-on: partial outsourcing allowed for the first time | Facility criteria premised on in-house interpretation revised. Under conditions including at least 80% in-house interpretation by the next working day, up to 20% may be outsourced to another insured institution. A "tier 2 (partial outsourcing)" category was set | Tier 2 (partial outsourcing) 166 pts / tier 2 175 pts / tier 3 235 pts (category names and points require verification) | Medium–High |
| Teleradiology | The outsourcing allowance expands the institutional standing of teleradiology services (also expanding the market for receiving centres and university hospitals) | Verify | Medium |
| AI imaging (software as a medical device, CAD) | No new fee schedule evaluation identified (the existing framework, including AI-assisted interpretation management under imaging management add-on tiers 3 and 4, appears to continue) | — (verify) | Low |
| MRI imaging (E202), 3T and above increased | Scans on 3T-or-higher machines +100 pts (cross-specialty) | Shared use 1,620 → 1,720; other 1,600 → 1,700 (verify) | Medium |
2. What it means for the practice
(1) There is now an alternative to giving up the add-on. Hospitals where the workload on staff radiologists has hit its limit previously faced a binary: keep pushing, or forfeit the add-on and interpretation revenue with it. A 20% outsourcing allowance with tier 2 (partial outsourcing) at 166 points sits 9 points below tier 2 at 175 — but overwhelmingly above forfeiting. Set up outsourcing contracts and interpretation-rate monitoring (the in-house 80% and next-working-day rules), then consider filing.
(2) Interpretation-rate tracking becomes new administrative work. "At least 80% in-house by the next working day" is a requirement you cannot hold unless it is measured and recorded. You need a way to continuously track the ratio of outsourced to in-house interpretations.
(3) Receiving centres have a market tailwind. Reading centres, university hospitals, and freelance radiologists see the market widen. SLA design around price and turnaround time becomes the competitive edge.
(4) AI-CAD was again not given its own fee. Adoption should be judged on interpretation productivity and recruiting strength, not on the fee schedule.
3. Practical checklist
- Have you confirmed your current imaging management add-on filing category?
- Can you measure and record the in-house interpretation rate (80% by the next working day)?
- Have you set up contracting with partner institutions for outsourcing?
- Have you calculated the point difference between partial-outsourcing tier 2 and your current category?
- Is the 3T MRI billing category (shared use vs other) set correctly?
- (Receiving side) Have you designed turnaround time and pricing SLAs?
4. Where an AI-native EMR fits — feature by feature
In 2026 this specialty gained operational freedom in where interpretation happens — and a responsibility to measure the result. Here is how Pottech's AI-native EMR helps, feature by feature.
Feature 1: Management analytics dashboard — measure the interpretation rate
Visit volumes, revenue per patient, and monthly trends are aggregated and visualized automatically.
"At least 80% in-house by the next working day" is a requirement you cannot know you are meeting unless you measure it. Outsourced volume, in-house volume, and time to interpretation, tracked continuously, are what sustain the filing. They also inform which category to target: partial-outsourcing tier 2 at 166, tier 2 at 175, or tier 3 at 235.
Feature 2: External integration and APIs — connect to teleradiology
An OAuth2 gateway, MCP server, and HAPI FHIR support allow integration with external systems.
Now that outsourcing is institutionally permitted, assembling images and request information by hand for each case makes it impossible even to use the 20% allowance. A standards-based integration layer determines whether outsourcing can be operated at all. For receiving centres, connecting smoothly to referring institutions is what turns into a turnaround-time advantage.
Feature 3: Billing and claims management — reflect category changes on the claim
The automatic billing engine checks bundling, mutual exclusions, and frequency limits.
The imaging management add-on gained a "partial outsourcing" category, and 3T MRI points changed. Newly subdivided items keep looking normal on the surface even when claims are still submitted under the old category. Having the billing category derived automatically from the machine used and whether outsourcing occurred prevents both lost increases and overbilling.
Also review what applies to every specialty
Consultation fees, the inflation add-on, the wage increase evaluation fee, and the electronic clinical information coordination add-on are collected in "what applies to every specialty."
Sources (principal)
- MHLW, "About the FY2026 Fee Schedule Revision" https://www.mhlw.go.jp/stf/newpage_67729.html
- ViewSend ICT (Jianrong Sijiang), "FY2026 fee revision: impact on diagnostic radiologists" https://mbp-japan.com/tokyo/viewsend-ict/column/5227501/
- Shirobon, "E202 magnetic resonance imaging (FY2026 fee table)" https://shirobon.net/medicalfee/latest/ika/r08_ika/r08i_ch2/r08i2_pa4/r08i24_sec3/r08i243_E202.html
- Tokyo Association of Medical Practitioners, "FY2026 revision: Chuikyo report (excerpt)" https://www.hokeni.org/docs/2026021200012/