Imaging center marketing: referrals and claims

An outpatient imaging center lives on orders. Most patients arrive with a physician order for an MRI, CT, ultrasound or mammogram, and then choose where to have it done, often based on cost, appointment times and how easy the center is to reach. A growing number of centers also sell self-pay and screening scans directly to consumers.

That makes imaging marketing a mix of two audiences, the referring offices and the patients, and two sets of federal rules that general marketing advice skips: the physician self-referral law and the anti-kickback statute on the referral side, and claim and billing rules on the patient side. This guide covers both, then lists marketing ideas that work inside them. For physician groups promoting their own scanners, labs and therapy to their own patients, see our guide to promoting in-office ancillary services. Thermography is not a screening substitute; see our guide to breast thermography advertising rules. Keepsake ultrasound studios are not medical imaging; see keepsake ultrasound studio marketing for what FDA has said.

This is general information, not legal or medical advice. Sources cited were checked on October 29, 2026: 42 U.S.C. 1395nn (physician self-referral law), 42 CFR 411.357 (exceptions), 42 U.S.C. 1320a-7b(b) (anti-kickback statute), 42 U.S.C. 1395m(e) (accreditation for advanced diagnostic imaging), 45 CFR 149.420 (No Surprises Act notice and consent), the FDA page Full-Body CT Scans: What You Need to Know (content current as of December 5, 2017), the FTC Health Products Compliance Guidance, Section 5 of the FTC Act (15 U.S.C. 45), 16 CFR 255.2, 16 CFR Part 465 and Google’s guidelines for representing your business. Have a health care attorney review your referral arrangements and marketing.

Imaging is a designated health service

The physician self-referral law, often called the Stark law, is the first thing to understand. 42 U.S.C. 1395nn(a) says that if a physician, or an immediate family member, has a financial relationship with an entity, the physician may not refer Medicare patients to that entity for designated health services, and the entity may not bill for services furnished under a prohibited referral, unless an exception applies. Section 1395nn(h)(6) lists radiology services, including magnetic resonance imaging, computerized axial tomography scans and ultrasound services, among the designated health services.

Financial relationships include ownership and investment interests and compensation arrangements. 42 CFR 411.357 sets out exceptions for compensation arrangements, such as office space and equipment rental, bona fide employment and personal service arrangements, each with its own conditions. For marketing, the practical rule is simple: any arrangement that gives a referring physician something of value, including free services, discounted space, staff time or paid speaking or advisory roles, needs counsel’s review before it starts.

The anti-kickback statute applies too

42 U.S.C. 1320a-7b(b) makes it a crime to knowingly and willfully offer or pay remuneration, directly or indirectly, in cash or in kind, to induce someone to refer an individual for items or services payable by a federal health care program. Unlike the self-referral law, it applies to anyone, not only physicians, and it depends on intent.

Common imaging marketing ideas that need counsel’s review under one or both laws:

Gifts, meals, event tickets or other items given to referring offices or their staff.
Paying a marketing company, lead vendor or individual per referred patient or per scan.
Free services to referring practices, such as staff to schedule scans in their office or free reads of images done elsewhere.
Discounted or free scans for referring physicians’ patients, staff or family.
Leases of space or equipment with a referring physician at other than fair market value or tied to referral volume.

Build referral relationships on information and service instead: fast scheduling, clear prep instructions, quick and readable reports, an easy way to reach a radiologist, and reliable results delivery. Our guide to patient and physician referrals covers the basics.

The same thinking applies when you exhibit to referring physicians at a medical meeting. Booth giveaways, sponsored dinners and paid speakers each put something of value in front of referral sources, and our guide to healthcare trade show marketing walks through how to plan them.

In-office MRI, CT and PET: the written notice rule

If your center is part of a physician group, or you compete with groups that image in their own offices, you should know the in-office ancillary services exception in 42 U.S.C. 1395nn(b)(2). For MRI, CT, PET and any other designated health services the Secretary specifies, it requires the referring physician to tell the patient in writing at the time of the referral that they may obtain the service from someone else, and to give the patient a written list of suppliers who furnish the service in the area where the patient lives.

For an independent imaging center, this is a reason to keep your contact details, locations and services accurate wherever lists of local suppliers are built. For a group with its own scanner, make sure the written notice and supplier list are part of the referral process before you market in-house imaging to patients.

Accreditation and equipment claims

Accreditation is a useful trust signal, and for some services it is a Medicare payment condition. Under 42 U.S.C. 1395m(e), beginning January 1, 2012, Medicare payment for the technical component of advanced diagnostic imaging services furnished by a supplier under the physician fee schedule may only be made if the supplier is accredited by an organization the Secretary has designated. The statute defines advanced diagnostic imaging to include diagnostic MRI, CT and nuclear medicine, including PET.

When you mention accreditation, name the accrediting body and the modalities and locations it covers, and keep it current. Do not imply that every modality or site is accredited if only some are. Describe equipment by what it does for the patient, such as a wider bore or shorter scan times, only if your radiologists and technologists confirm it for your actual scanners, and avoid superlatives such as the most advanced or the best images in the city unless you can prove them.

Self-pay and screening scans

Self-pay pricing helps patients with high deductibles compare options. If you advertise prices, say exactly what is included, such as the scan, the radiologist read and contrast if used, and what is not. Uninsured and self-pay patients are generally entitled to a good faith estimate; see our guide to good faith estimates for self-pay patients.

Screening scans sold directly to consumers need extra care. FDA’s page on full-body CT scans, last updated December 5, 2017, says FDA knows of no scientific evidence demonstrating that whole-body scanning of individuals without symptoms provides more benefit than harm to people being screened, and that FDA prohibits manufacturers of CT systems from promoting their use for whole-body screening of asymptomatic people, although it does not regulate how practitioners use them.

Section 5 of the FTC Act, 15 U.S.C. 45, prohibits deceptive acts or practices, and the FTC Health Products Compliance Guidance says health benefit claims, express or implied, require competent and reliable scientific evidence. Lines such as catch cancer early, peace of mind in one scan or a scan that could save your life are health benefit claims. If you offer screening scans, describe what the scan is, what it can and cannot show, the radiation involved where relevant, what happens if something is found, and that it does not replace care from the patient’s own clinician.

Whole-body MRI and other screening scans sold to healthy adults raise their own claim, safety and incidental finding questions. See our full-body MRI marketing guide.

No Surprises Act points for radiology

Radiology often reaches patients through a hospital or surgery center, which brings in the No Surprises Act. Under 45 CFR 149.420, a nonparticipating provider who furnishes non-emergency services at a participating health care facility generally may not bill the patient more than in-network cost sharing unless notice and consent criteria are met. 149.420(b) says the notice and consent option does not apply to ancillary services, including items and services related to radiology and diagnostic services including radiology and laboratory services.

In plain terms, an out-of-network radiology group reading scans at an in-network facility cannot use a consent form to balance bill for those services. Make sure your billing pages and patient FAQs do not suggest otherwise, and see our guide to No Surprises Act website disclosure for the notice providers and facilities post.

Reviews and patient stories

Under 16 CFR 255.2(b), an ad that tells one patient’s experience on a key point, such as a scan that found something in time, is likely to be read as showing what patients will generally experience, so without substantiation that it is representative, the ad should clearly disclose the generally expected results. The FTC rule on consumer reviews and testimonials, 16 CFR Part 465, prohibits fake reviews, and section 465.4 prohibits incentives conditioned on reviews expressing a particular sentiment. Using a patient’s story or images in marketing generally requires written authorization under HIPAA; see our guide to HIPAA marketing rules, and our guide to replying to patient reviews.

Imaging center marketing ideas that work inside the rules

A page for each modality. MRI, CT, ultrasound, mammography, X-ray and any others you offer: what the exam involves, how long it takes, how to prepare, and how results reach the patient and the ordering clinician.
A referral page for ordering offices. How to send orders, scheduling turnaround, prep instructions to give patients, how reports are delivered and how to reach a radiologist.
Clear self-pay information. Prices with what is included, how to ask for a good faith estimate, and accepted insurance listed accurately.
Online scheduling or request forms. Ask only for what you need, and keep order details and health information away from advertising tools; see our guide to tracking pixels on practice websites.
An accurate Google Business Profile for each location. Google’s guidelines require the business name, address and categories to reflect the real business, with accurate hours, including evening and weekend scanning hours; see our guide to Google Business Profile for doctors.
Tracking by source. Know which offices, searches and campaigns bring orders and self-pay bookings, as described on our medical lead generation page, without paying anyone per referral.

Can we take referring physicians to lunch?

Ask counsel first. Both the physician self-referral law, 42 U.S.C. 1395nn, and the anti-kickback statute, 42 U.S.C. 1320a-7b(b), can apply to things of value given to referral sources. Many centers compete on scheduling speed, reports and service instead.

Can we pay a marketing company per scan it brings in?

Have counsel review it before you start. Paying per referred patient for services payable by a federal health care program can raise anti-kickback concerns under 42 U.S.C. 1320a-7b(b).

Do we have to be accredited to advertise MRI?

Advertising is not the trigger, but under 42 U.S.C. 1395m(e) Medicare pays for the technical component of advanced diagnostic imaging furnished by a supplier only if the supplier is accredited by a designated organization. Describe your accreditation accurately, by modality and location.

Can we market full-body scans to healthy people?

If you do, avoid health benefit claims you cannot substantiate. FDA says it knows of no scientific evidence that whole-body CT screening of people without symptoms provides more benefit than harm, and the FTC requires competent and reliable scientific evidence for health claims.

Can an out-of-network radiologist get patient consent to balance bill?

Not for services at an in-network facility. 45 CFR 149.420(b) excludes ancillary services, including radiology and diagnostic services, from the notice and consent option.

Sources

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Imaging center marketing: physician referrals, self-referral rules and patient-facing claims