Imaging diagnostic centers and hospital radiology departments are trying to understand, in light of the new federal information blocking policy, when radiology reports should be published to patients and whether those reports should be available immediately to patients once completed. It is helpful to consider the response to somewhat similar legislation enacted in Pennsylvania and how image providers have responded.
The Patient Testing Information Act (Act 112) was enacted by the Pennsylvania General Assembly in 2018, but did not apply until the end of 2019. The law requires direct notification to patients. of “significant” abnormalities in imaging studies, that is, those findings “that cause a reasonably prudent person to seek additional or follow-up medical attention within three months”. Imaging diagnostic facilities should directly notify outpatients within 20 days of the imaging study of significant imaging abnormalities. Pennsylvania imaging centers are not required to send a copy of the radiology report itself or even describe the significant patient-specific abnormality. Rather, the legislation requires the use of specific language in the notice that states, “You are receiving this notice as a result of the determination of your diagnostic imaging service that other debates about the results are warranted. of the tests and that would be beneficial to you.the results of the test or tests have been sent or will be sent to the doctor who ordered the test or tests.It is recommended that you contact your doctor to discuss the results as soon as possible. “
In a featured perspective article in the Journal of the American College of Radiology, three radiologists practicing in the Commonwealth of Pennsylvania described the practical implementation challenges arising from compliance with Act 112. The authors noted that what is considered a Significant abnormality could be minor – such as a possible rib fracture, or it could be more disastrous, such as lung cancer. But a patient who receives the warning has no way of knowing the importance of the “abnormal” finding. The anxiety these letters have produced in Pennsylvania-resident patients is not surprising.
When the implementation of Act 112 began, Pennsylvania imaging facilities began to face complaints from doctors who requested imaging studies for their patients, particularly anxious patients contacted. physicians to obtain results from imaging studies before these physicians had the opportunity to review the radiology report. The authors noted:[i]Imposing a moratorium on the time the letter is shipped can alleviate some of these problems by giving the ordering provider more time to review the radiology report. However, this may be a problem, as Law 112 requires the letter to be sent within 20 days. It can be difficult for order providers in all areas of practice to always review patient image reports under their care within 20 days, especially in the paradigm of modern practice where they are forced to see more patients in less time “.
This raises the question of whether the rule of blocking information will require patients to have immediate access to radiology reports through secure patient portals or by other means.
According to the guidelines of the Office of the National Coordinator (ONC) of Health Information Technologies, it seems likely that imaging centers and hospital radiology departments will have to opt for immediate patient access to these reports. if it is considered that delays in the presentation of test results are unreasonable and probable. to interfere with the access, exchange or use of electronic health information. Frequently asked questions published by the ONC indicate that policies to embargo the publication of test results could be considered “interference” for information blocking purposes and recommend that a patient be able to access test results “in parallel. To the availability of the test results to the clinician in charge “.
Undoubtedly, the good intentions of the legislation on Pennsylvania test results, combined with the expected requirements of the Information Blocking Standard, have created a “perfect storm” for imaging facilities. and physicians requesting diagnostic tests in this state.
Some order providers have complained about the increase in the number of patient calls asking about the results of an imaging study before the provider has had a chance to review the radiology report. One solution of the health care system to these complaints was to develop a new workflow that uses medical extenders tasked with calling doctors asking for orders directly before sending the Act 112 letter.
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