By the VerifyDoc team
When you get an imaging scan, you can legally receive two separate bills — one from the hospital or imaging center and one from the radiologist — but a surprising number of those bills contain errors that result in double charges, inflated costs, or payments for services that weren't rendered.
This post explains exactly how radiology's professional component (PC) and technical component (TC) split billing works, what federal regulations govern it, and the five most common mistakes patients encounter when reviewing imaging bills. If you've ever wondered why your MRI generated invoices from two completely different entities, you'll have a clear answer by the end.
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Check my bill — free preview →How Radiology Split Billing Actually Works
Most radiology services, though described by a single CPT code, comprise two distinct portions: a professional component and a technical component. The professional component is provided by the physician and includes supervision, interpretation, and a written report. The technical component covers the provision of all equipment, supplies, personnel, and costs related to the performance of the exam.
CMS designates many imaging codes as "PC/TC indicator 1" codes, meaning they can be billed as a global service, as a technical component only, or as a professional component only. The CMS assigns these indicators in the Medicare Physician Fee Schedule Relative Value File, which is publicly available. According to CMS, the professional component is defined as physician work interpreting a diagnostic test or performing a procedure, including indirect practice and malpractice expenses related to that work — and modifier 26 is used with the billing code to indicate that the PC is being billed. The technical component covers all non-physician work, including administrative, personnel, and capital (equipment and facility) costs and related malpractice expenses — and modifier TC is used with the billing code to indicate that the TC is being billed.
Unlike most medical specialties, a single imaging study routinely produces two simultaneous claims from two different entities. A hospital submits the TC claim; the radiologist's group submits a separate CMS-1500 claim with modifier 26. Both payments combined must equal — but not exceed — the global rate. If one entity provides both components, the global code is billed without any modifier. When reviewing your imaging bills, understanding this structure is the starting point for spotting errors. You can learn more about how multiple invoices arrive from a single visit in our post on provider-based billing: why one visit sends two bills in 2026.
Mistake #1: Paying a Global Bill When Two Separate Bills Are Correct
Many patients assume that receiving a single bill from a hospital or imaging center means all services are included. That's often wrong. For hospital outpatient departments, the technical component is included in the facility's claim on a UB-04 form, while the radiologist submits a separate CMS-1500 form with modifier -26 for the professional component.
If the provider who interprets the film also owns the equipment, a global service is submitted and the professional and technical components are billed together — the appropriate CPT code is reported without either modifier 26 or TC appended. But if the radiologist interpreting your images works for an independent group that doesn't own the equipment, a global code billed by the facility is an error — the facility should bill only TC, and the radiologist's group should bill only with modifier 26. Seeing a global code on your hospital bill and a separate professional component bill from a radiology group? That's the double-billing pattern described in Mistake #2 below.
Mistake #2: Not Catching Global + Component Double-Billing
The most financially damaging pattern in radiology billing is when the facility bills the global imaging code and the radiologist also bills a separate professional component. The facility bills the global imaging code — which includes both technical and professional components — while the radiologist also bills the professional component separately. This results in the professional interpretation being billed twice.
When both the facility and the radiologist bill separately, they should use the TC and modifier 26 respectively. Billing the global code plus either component is a common error. If your insurer's Explanation of Benefits (EOB) shows the same CPT code billed once without a modifier and again with modifier 26 on the same date of service, flag it immediately. You can dispute this type of charge — our guide on what "adjustments" on a hospital bill really mean in 2026 explains how to read the EOB figures that reflect these payment conflicts.
This pattern is specifically monitored by federal oversight. Component billing errors — billing global when only one component was provided, using -26 on a code that does not support split billing, or missing -TC — account for a significant share of payment variances in radiology. The HHS Office of Inspector General has an active work plan item targeting duplicate Medicare professional fee billing related to these component splits.
Mistake #3: Accepting a Modifier 26 Charge on a Code That Doesn't Allow It
Not every CPT code supports a professional/technical split. Modifier 26 is exclusively for diagnostic tests and procedures that have both a technical and a professional component as defined by CMS. It cannot be used on surgical codes (CPT 10000–69999 series) or Evaluation and Management (E/M) services. Using it on an incorrect code type will result in an immediate denial.
A particularly common error involves lab tests. Modifier 26 is appropriate to report with diagnostic imaging services — such as radiology, CT, and MRI — and pathology services. It is not appropriate to report with clinical laboratory testing codes. If you see modifier 26 appended to a routine blood test or urinalysis on your itemized bill, that's a red flag worth disputing. The right way to check: to determine whether a CPT or HCPCS code allows the TC modifier, check the code's current PC/TC indicator in the CMS Physician Fee Schedule. The full fee schedule is publicly searchable at cms.gov at no cost.
Our related post on NCCI edits and improperly split procedure pairs covers the broader framework of when separate billing is and isn't permitted — the same logic applies here.
Mistake #4: Missing a TC Overcharge for Hospital Inpatients
Federal law places a hard stop on who can bill the technical component for hospital inpatients — and most patients don't know this rule exists. The Social Security Act § 1862(a)(14) and 42 CFR § 411.15(m) require that when the TC of a radiology service is furnished to an inpatient of a hospital by any entity other than the hospital, the TC is excluded from coverage unless performed under arrangement in which the hospital must bill the intermediary.
When the TC of a radiology service is provided to an inpatient under arrangement by a physician or supplier, only the hospital may bill Medicare for those services. What this means for patients: if you were admitted as a hospital inpatient and you received a separate TC bill from a freestanding radiology group or imaging company, that charge is improper under federal rules. Check your admission status — whether you were classified as inpatient or outpatient matters enormously here. Our post on observation vs. inpatient admission billing differences walks through exactly how to confirm your status.
Mistake #5: Overlooking Place-of-Service Errors That Change Your Cost
Payers apply the place of service code — for example, POS 22 for on-campus outpatient hospital — in determining whether global billing is appropriate or prohibited. The place-of-service code on the radiologist's claim must reflect where you, the patient, received the technical service — not where the radiologist was physically sitting when they read your images.
When a radiologist provides an interpretation remotely for a study performed at a hospital, the billing logic remains the same. The radiologist's practice bills with modifier 26 appended to the appropriate CPT code. The Place of Service code on the claim should reflect where the patient received the technical service — for example, POS 21 for Inpatient Hospital — not where the radiologist is physically located. When a practice uses a non-facility POS code incorrectly, it can trigger higher reimbursement than the rules allow — and in some cases, result in higher cost-sharing for you.
Under 42 CFR § 415.120, the carrier pays for radiology services furnished by a physician to a beneficiary on a fee schedule basis only if the services are identifiable, direct, and discrete diagnostic or therapeutic services furnished to an individual beneficiary — such as interpretation of x-ray plates, angiograms, myelograms, pyelograms, or ultrasound procedures. A vague line item like "radiology services" without a specific CPT code and modifier doesn't meet that standard. Always request a fully itemized bill.
Quick Reference: PC/TC Split Billing Error Types at a Glance
| Error Type | What It Looks Like on Your Bill | Governing Rule | What to Do |
|---|---|---|---|
| Global + component double-billing | Same CPT code billed without modifier AND with modifier 26, same date | CMS Claims Processing Manual, Ch. 13 | Request itemized bill; dispute duplicate line |
| Modifier 26 on ineligible code | Modifier 26 appended to a lab test or E/M service CPT code | CMS PC/TC Indicator ≠ 1 | Check CMS fee schedule; dispute the modifier charge |
| TC billed to inpatient by outside vendor | Separate TC invoice from imaging company during inpatient stay | 42 CFR § 411.15(m) | Confirm inpatient status; dispute TC bill; contact insurer |
| Wrong Place of Service code | Radiologist claim shows non-facility POS for a hospital-based scan | 42 CFR § 415.120; CMS Ch. 13 | Request CMS-1500 claim form; verify POS code matches facility |
| Global bill when split was appropriate | Hospital bills full global code; independent radiologist has no claim | CMS Claims Processing Manual, Ch. 13 | Verify radiologist's group affiliation; confirm who billed what |
How to Check Your Own Radiology Bill in 2026
Start by requesting two documents: your fully itemized hospital or imaging center bill and your Explanation of Benefits from your insurer. The itemized bill must show every CPT code and modifier charged. The EOB shows what was actually paid to each provider. Compare them side by side.
As of January 1, 2026, there are no changes to the definition or usage rules for modifier 26. The CY 2026 Medicare Physician Fee Schedule final rule updated payment rates and relative value units but maintained existing modifier 26 guidelines. This matters because any billing office claiming the rules changed to justify an unusual charge is not being accurate. The CMS CY 2026 Physician Fee Schedule Final Rule (CMS-1832-F), released October 31, 2025, introduced two separate conversion factors for the first time: $33.57 for qualifying APM participants and $33.40 for non-qualifying participants. Payment rates changed — the rules for what can be split-billed did not.
If you believe a radiology bill contains a PC/TC error, the appeal process has firm deadlines. A Modifier 26 appeal letter should include patient information, claim number, date of service, CPT code, modifier, denial reason, explanation of correct billing, supporting documentation, and regulatory references — specifically CMS Claims Processing Manual Chapter 13 and 42 CFR § 415.120. Medicare gives you 120 days from the initial determination. Commercial payers vary, typically 60 to 180 days. Don't wait. Our guide on how to read every line of your itemized hospital bill walks through the mechanics of pulling and interpreting these documents.
About VerifyDoc: We help patients identify errors and overcharges on medical bills. We publish guides on hospital billing, the No Surprises Act, and disputing medical charges, updated as federal and state rules change.
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Check my bill — free preview →Frequently asked questions
Why did I receive two separate bills after my MRI — one from the hospital and one from a radiology group?
This is normal and legal when two different entities provide the two components of the imaging service. The hospital or imaging center bills for the technical component (the equipment, technician, and facility costs) using modifier TC. The radiologist who interpreted your images bills separately for the professional component using modifier 26. Under CMS rules, each entity bills only for the portion it actually provided. What is not normal is if you see the same CPT code billed globally by the hospital and also billed with modifier 26 by the radiology group on the same date — that's a double-billing pattern worth disputing.
How do I know if my radiologist's bill is using the right CPT code modifier?
Ask for your itemized bill and look at the CPT code, then check whether it carries modifier 26 or TC. You can then look up that CPT code in the CMS Physician Fee Schedule Relative Value File, which is free at cms.gov, to confirm whether it carries a PC/TC Indicator of 1 — meaning a split is permitted. If the code carries a PC/TC Indicator of 0, 2, 3, or 4, split billing with modifier 26 is either prohibited or not applicable. Modifier 26 cannot be used on E/M codes or surgical procedure codes, so if it appears on those code types, the charge is incorrect.
I was admitted as a hospital inpatient and got a separate TC bill from an imaging company. Is that allowed?
No. Under 42 CFR § 411.15(m) and Social Security Act § 1862(a)(14), when the technical component of a radiology service is furnished to a Medicare hospital inpatient by an entity other than the hospital itself, that TC charge is excluded from Medicare coverage unless it was performed under a formal arrangement where the hospital bills the intermediary. If you were a confirmed inpatient and received a separate TC invoice from an outside imaging vendor, dispute it with your insurer immediately and reference this federal rule. First confirm your admission status — inpatient versus observation — because the rules differ depending on your official classification.
If I spot a billing error on my radiology bill, how do I dispute it and how much time do I have?
Start by gathering your itemized bill, your Explanation of Benefits, and the radiology report. Write a dispute letter that identifies the patient, claim number, date of service, the specific CPT code and modifier, the error type, and the regulatory basis for your dispute — citing CMS Claims Processing Manual Chapter 13 and 42 CFR § 415.120 where relevant. Medicare gives patients 120 days from the initial determination to appeal. Commercial insurers typically allow 60 to 180 days, but check your plan documents for the exact window. Send everything in writing, keep copies, and follow up every two to three weeks until you receive a written resolution.