A Medicare portable X-ray supplier (PXRS) is a certified supplier that brings X-ray services to patients and must meet the conditions for coverage in 42 CFR Part 486, Subpart C. Portable X-ray supplier certification readiness is for mobile radiology operators serving facilities or patients outside a fixed imaging center. Integral Healthcare Solutions (IHS) organizes your portable X-ray supplier policies and evidence against those conditions; your radiology leaders and physicist own imaging and radiation safety, and your organization files and works with CMS and the state.
Last reviewed: October 2026.
What is a Medicare portable X-ray supplier?
The governing text is 42 CFR Part 486, Subpart C, "Conditions for Coverage: Portable X-Ray Services," §§ 486.100 to 486.110 (eCFR, current as of 30 September 2026). CMS lists portable X-ray suppliers among the organizations subject to conditions of participation or coverage (CMS). Enrollment is covered in the CMS Program Integrity Manual (Pub. 100-08), Chapter 10, § 10.2.2.8, "Portable X-Ray Suppliers (PXRSs)," as revised by Transmittal 11574, issued 25 August 2022 (CMS Transmittal 11574). We read the transmittal; CMS may have revised Chapter 10 since, so check the current chapter.
The transmittal states: "PXRSs are a certified supplier type that enroll via the Form CMS-855B," and "To qualify as a PXRS, an entity must meet the conditions for coverage discussed in 42 CFR § 486.100-110" (Transmittal 11574).
The conditions set out who supervises, who performs and who orders the work:
- "Portable X-ray services are provided under the supervision of a qualified physician" (42 CFR 486.102).
- "Portable X-ray services are provided by qualified technologists" (42 CFR 486.104).
- "Portable X-ray examinations are performed only on the order of a physician licensed to practice in the State or by a nonphysician practitioner acting within the scope of State law" (42 CFR 486.106(a)).
Who needs it and what triggers it
The buyers are mobile radiology operators that serve facilities or patients outside a fixed imaging center and bill Medicare as a portable X-ray supplier. The work usually starts with one of these:
- Initial Medicare enrollment. A new supplier enrolls on the CMS-855B and must meet the conditions for coverage (Transmittal 11574).
- A state survey. CMS states that "A PXRS requires a state survey, while a mobile IDTF does not (although an IDTF requires a site visit)" (Transmittal 11574).
- Choosing between enrollment routes. A mobile imaging business has to decide whether it enrolls as a portable X-ray supplier, a mobile independent diagnostic testing facility (IDTF), or both (see "How it compares" below).
How IHS helps
- Confirm the route. Your team decides whether the business enrolls as a portable X-ray supplier or a mobile IDTF. IHS sets out what each route requires so the decision is made before documents are written.
- Gap assessment. IHS compares your operation with the 42 CFR Part 486, Subpart C conditions, using questionnaires on supervision, personnel and equipment.
- Evidence crosswalk. IHS maps each condition to the record or procedure that shows you meet it.
- Drafting. IHS drafts service records, ordering and record-retention procedures and supervision procedures for your supervising physician and radiology leaders to review and approve.
- Mock survey. IHS walks the evidence against the conditions as a surveyor would and lists what is missing.
- Readiness support. IHS drafts enrollment correspondence for your organization to send.
What you supply: equipment and personnel records, supervising physician details, current procedures, and sign-off from your radiology leaders and physicist.
The limit: radiation protection, imaging protocols and equipment performance need a qualified physicist and radiologist. IHS does not judge them. Your organization files its enrollment and deals with CMS, its contractors and the state survey agency; IHS drafts.
What to have ready
Each item ties to 42 CFR Part 486, Subpart C (eCFR, current as of 30 September 2026), CMS Transmittal 11574, or 42 CFR 424.514.
- A decision on your enrollment route, portable X-ray supplier, mobile IDTF or both, since CMS treats them differently (Transmittal 11574).
- The name and qualifications of the physician who supervises the service (42 CFR 486.102).
- Qualification records for each technologist who performs examinations (42 CFR 486.104).
- An orientation program that covers "Precautions to be followed to protect the patient from unnecessary exposure to radiation" and "Proper maintenance of records" (42 CFR 486.104).
- An ordering procedure that accepts orders only from a physician licensed in the state or a nonphysician practitioner acting within the scope of state law (42 CFR 486.106(a)).
- A records procedure that keeps reports "for a period of at least 2 years, or for the period of time required by State law for such records ... whichever is longer" (42 CFR 486.106(c)).
- Equipment and safety records for §§ 486.108 to 486.110, which cover safety standards and inspection of equipment, reviewed by your physicist (42 CFR Part 486, Subpart C).
- A completed CMS-855B enrollment application (Transmittal 11574).
- The application fee, or a request for a hardship exception filed with the application (42 CFR 424.514(a)).
- A plan for the state survey (Transmittal 11574).
If you would like to go through this list against your own operation, start with an introductory call.
How it compares
The main alternative for a mobile imaging business is enrollment as a mobile IDTF under 42 CFR 410.33. CMS states that "A PXRS can be simultaneously enrolled as a mobile independent diagnostic testing facility (IDTF), though they cannot bill for the same service" (Transmittal 11574).
| Portable X-ray supplier | Mobile IDTF | |
|---|---|---|
| Governing text | 42 CFR Part 486, Subpart C | 42 CFR 410.33 |
| Enrollment form | CMS-855B (Transmittal 11574) | CMS-855B (MLN909060) |
| Onsite check | A state survey (Transmittal 11574) | No state survey; a site visit (Transmittal 11574) |
| Who orders | A physician licensed in the state, or a nonphysician practitioner within the scope of state law (486.106(a)) | "the physician who is treating the beneficiary," in writing (410.33(d)) |
| Supervision | A qualified physician (486.102) | Each supervising physician limited to general supervision of no more than three IDTF sites (410.33(b)(1)) |
For the IDTF route, CMS also states that "Each IDTF mobile unit must enroll separately" (MLN909060), and the regulation requires "a comprehensive liability insurance policy of at least $300,000 per location" (42 CFR 410.33(g)(6)). CMS's IDTF booklet adds that "A mobile IDTF doesn't include entities that lease or contract with a Medicare-enrolled provider or supplier to provide" equipment or personnel (MLN909060). The sources we reviewed do not say how that leasing language applies to portable X-ray suppliers.
What it costs
CMS publishes the Medicare enrollment application fee. For calendar year 2026 it announced "a $750.00 calendar year (CY) 2026 application fee for institutional providers that are initially enrolling in the Medicare or Medicaid program" (Federal Register 2025-21877). The notice defines an institutional provider to include suppliers that enroll on the CMS-855B, other than physician and non-physician practitioner organizations. IHS's reading (October 2026): because portable X-ray suppliers enroll on the CMS-855B, an initial enrollment pays this fee unless a hardship exception is granted under 42 CFR 424.514(a). Verify current fees with CMS. We did not review state survey or radiation registration fees.
IHS scopes each engagement after a free introductory call.
What this is not
- IHS does not assess radiation protection, imaging protocols or equipment performance. Those need your qualified physicist and radiologist.
- IHS does not guarantee the outcome of a state survey or a Medicare enrollment decision.
- IHS does not file enrollment or communicate with CMS, its contractors or the state for you. This page is not legal advice.
Frequently asked questions
What is a Medicare portable X-ray supplier?
CMS describes portable X-ray suppliers as a certified supplier type that enrolls on the Form CMS-855B. To qualify, an entity must meet the conditions for coverage in 42 CFR 486.100 to 486.110, which cover physician supervision, qualified technologists, ordering, records and equipment safety.
Portable X-ray supplier versus mobile IDTF: which enrollment does my mobile imaging business need?
That depends on how your business is set up, and the decision is yours. The two routes differ: a portable X-ray supplier meets 42 CFR Part 486, Subpart C and requires a state survey, while a mobile IDTF meets 42 CFR 410.33 and has a site visit instead of a state survey. IHS sets out what each route requires before drafting begins.
Can we be enrolled as both a portable X-ray supplier and a mobile IDTF?
Yes. CMS Transmittal 11574 states that a portable X-ray supplier can be enrolled at the same time as a mobile IDTF, though the two cannot bill for the same service.
Does a portable X-ray supplier need a state survey?
Yes. CMS Transmittal 11574 states that a portable X-ray supplier requires a state survey, while a mobile IDTF does not, although an IDTF requires a site visit.
What training must portable X-ray technologists have?
42 CFR 486.104 requires that services be provided by qualified technologists. The same section lists personnel orientation topics, including precautions to protect the patient from unnecessary exposure to radiation and proper maintenance of records.
Who can order portable X-ray services for Medicare patients?
Under 42 CFR 486.106(a), examinations are performed only on the order of a physician licensed to practice in the state, or a nonphysician practitioner acting within the scope of state law.
What records must a portable X-ray supplier keep, and for how long?
42 CFR 486.106(c) requires that reports be kept for at least 2 years, or for the period state law requires for such records, whichever is longer. The regulation distinguishes these records from requirements for the radiograph itself.
What radiation safety topics must staff orientation cover?
42 CFR 486.104 lists precautions to be followed to protect the patient from unnecessary exposure to radiation among the orientation topics, along with proper maintenance of records. Your physicist and radiology leaders own the radiation safety content itself.
Which Medicare enrollment form does a portable X-ray supplier file, and is there a fee?
Portable X-ray suppliers enroll on the CMS-855B, according to Transmittal 11574. CMS set a $750.00 application fee for calendar year 2026 for institutional providers initially enrolling. IHS's reading (October 2026) is that this fee applies to an initial portable X-ray supplier enrollment unless a hardship exception is granted. Verify current fees with CMS.