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Radiology regulations and how we got here

November 20, 2016
Business Affairs
From the November 2016 issue of HealthCare Business News magazine

By Saud Juman

Each radiology department has unique characteristics and dynamics that reflect the diverse group of people who make up the medical imaging team.

This includes clinicians, ancillary care providers and technicians, among others. Policy management becomes very important in departments such as radiology/imaging, where staff is dealing with upkeep of hardware and also providing for required diagnostic services, and radiologic therapeutic care, for example, in oncology patients undergoing radiation treatment. The policies that govern these procedures are very detailed in terms of specifying dosages and criteria to follow. The imaging policy and procedure requirements have also changed tremendously over the last three years.

If the Joint Commission regulates a given health care organization, then these policies and procedures must be updated to meet current regulatory requirements. Aside from meeting such requirements, imaging policies and procedures are required to be reviewed and updated annually to keep them current with emerging and advancing technologies, processes and management decisions.

The 2014 Joint Commission standards and the Protecting Access to Medicare Act, commonly called the sustainable growth rate (SGR) patch, included components that must be reflected in an organization’s imaging policies and procedures. The following are some examples from current Joint Commission requirements:

All individuals performing CT procedures must be registered with the American Registry of Radiologic Technologists or the Nuclear Medicine Technology Certification Board.
Health care providers must have a robust internal radiation safety program that includes a strong ongoing education/ training component, based on the Image Gently and Image Wisely campaigns.
Health care providers who render CT imaging services must report each patient’s radiation dose (CT dose index and dose length product) information in the diagnostic imaging report, as well as make it part of the patient’s medical record.
For the elements of performance, health care providers must have adult and pediatric CT imaging protocols benchmarked and reviewed annually by a physicist.
ACR and AAPM benchmarks are recommended, but not enforced.
Ordering physician decision support for advanced imaging procedures.
Improved and stricter patient radiation dose safety controls and levels.
CT equipment must meet the National Electrical Manufacturer Association standards. Medical imaging departments also face a common challenge of keeping up with radiation dose management policies and procedures. Basic tasks, including figuring out where to start, become resource-intensive efforts in the absence of automated policy management solutions.

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