The Joint Commission has recently announced new and revised diagnostic standards for accredited hospitals, critical access hospitals and ambulatory healthcare organizations that provide diagnostic imaging services.1
Medical experts have emphasized the importance of facilities utilizing diagnostic imaging to take necessary precautions to minimize the risk of radiation exposure. While experts may have differing views on the risks of cancer from diagnostic imaging, there is agreement that care should be taken in weighing the necessity of a given level of radiation against those risks, and steps should be taken to eliminate avoidable radiation exposure and long-term damage.2 The fact that diagnostic imaging has become increasingly available to patients has also meant that the country’s exposure to ionizing radiation has almost doubled in the past 20 years.3 In light of these statistics, many healthcare providers have worked to restructure their radiation safety standards by focusing on areas such as CT protocols, development of incident management policies and procedures, and procurement of new technologies and software to track and monitor radiation dosage.4 The Joint Commission’s new imaging standards will target those states and/or healthcare providers that have yet to adopt such safety measures.
After recognizing the need to more heavily regulate quality and safety issues in radiology, The Joint Commission met with and took recommendations from diagnostic imaging experts, professional associations and accredited organizations to devise these new standards, which not only expand upon the existing requirements but also ensure that imaging protocols remain current.5 This was achieved by focusing on patient safety, including radiation safety, oversight of imaging services, overall staff competency and equipment maintenance.6 According to The Joint Commission Executive Vice President, Margaret VanAmringe, the intended goal is to “ensure that organizations providing imaging services have the requisite infrastructure and safety culture to minimize radiation exposure to patients and staff and provide safe and effective care.”
The safety standards addressed in the prepublication requirements include: (i) managing safety and security risks involving patients with special circumstances, such as claustrophobia or medical implants; (ii) risk management related to hazardous materials and waste, including assessment of staff radiation exposure levels by a radiation safety officer or medical physicist; (iii) annual performance evaluations of all imaging equipment by a diagnostic medical physicist; (iv) mandatory ongoing education for radiologic technologists, including training in radiation dose-reduction techniques; (v) minimum competency for radiology technicians, including registration and certification by July 1, 2015, by either The American Registry of Radiologic Technologists or the Nuclear Medicine Technology Certification Board; (vi) documentation of CT radiation doses in the patient’s clinical record; and (vii) continuing collection of data on radiology incidents and injuries.7
These changes will be implemented in phases. The first phase, which will take effect July 1, 2014, will focus on CT, nuclear medicine, PET and MRI. The second phase is to be implemented by July 1, 2015, and will focus on fluoroscopy, required qualifications for imaging clinicians, and cone beam CT used in dental offices and oral-maxillary surgery practices.
While compliance with these new standards is important for all facilities seeking to maintain The Joint Commission accreditation, it is equally important for the facilities and hospitals that intend continued participation in Medicare and Medicaid reimbursement programs. Since Jan. 1, 2012, Medicare has required that advanced diagnostic imaging — including MRI, CT, PET and nuclear medicine imaging — be billed by those providers which are accredited by one of the Centers for Medicare & Medicaid Services-approved accrediting organizations.8 Hospitals and other imaging facilities will have until July 1, 2014, to meet the newly revised radiation safety rules, or risk losing The Joint Commission accreditation, as well as Medicare and Medicaid participation. It is recommended that the new requirements in the 2014 Ambulatory Care, Critical Access Hospitals, and Hospital Comprehensive Accreditation Manual, published in March, be carefully reviewed in order to ensure up-to-date compliance.9
Thomas A. Mobilia is a Senior Partner and trial attorney at Martin Clearwater & Bell LLP who has defended the firm’s hospital clients, medical practices and physicians in high-exposure malpractice cases in state and federal courts for more than 20 years. Mobilia also represents physicians and healthcare professionals in disciplinary proceedings brought by the New York State Department of Health, Office of Professional Medical Conduct and Office of Professional Discipline.
Melanie G. Gelfand is an Associate at Martin Clearwater & Bell LLP and focuses her practice on medical malpractice defense.
- Radiation Risks of Diagnostic Imaging, 47 The Joint Commission Sentinel Event Alert 1, (2011) (hereinafter “Sentinel Event Alert”).
- Neomi Mullens, Are You Ready to Comply with New Radiation Safety Rules?, AuntMinnie.com (February 6, 2014); http://www.auntminnie.com.
- Elizabeth Eaken Zhani, Joint Commission Announces New and Revised Diagnostic Imaging Standards, The Joint Commission (February 6, 2014); http://www.jointcommission.org
- Zhani, supra note 6.
- See The Joint Commission Prepublication Standards at http://www.jointcommission.org.
- Medicare Coverage of Imaging Services, Department of Health and Human Services: Centers for Medicare & Medicaid Services, June 2013, available at https://www.cms.gov/.
- Zhani, supra note 6.