UPDATE 9/5: The bill discussed in this article was submitted, but didn’t make it through the hearing committee; therefore the dates and formal requirements are not applicable at this time.
By Neil Singh
September 2013—Following the Mad River Community Hospital and Cedars-Sinai radiation overexposure incidents, awareness and national coverage of radiation dose safety has increased tremendously, and it continues to gain momentum. California sparked a positive and progressive change in healthcare by introducing its radiation dose safety mandate SB1237 (AB510), which took effect July 1, 2012. Texas followed with its version of a radiation safety mandate, 25 Texas Administrative Code, §289.227, which details mandatory CT and interventional radiography imaging guidelines for healthcare providers in Texas.
Connecticut introduced Raised Bill 6423 in January 2013 and has projected the bill to take effect October 1, 2013. Healthcare providers in Connecticut performing CT and radiation therapy procedures will need to follow the guidelines below to be compliant.
Connecticut Mandate RB6423 (To be effective October 1, 2013):
- Healthcare providers performing CT scans shall record all dose information on the patient’s radiology report or attach a protocol page that includes the dose information from the CT scanner.
- The CT device shall be inspected annually, and the dose output shall not exceed more than 20% from the actual measured dose.
- The provider shall notify the Connecticut Department of Public Health (CTDPH), and the ordering physician of the following incidents within 5 days:
- If a repetition of a CT scan on a patient has been performed without an order from a physician.
- Irradiation of a body part other than the one ordered by the ordering physician.
- Any radiation exposure to a patient that causes hair loss, erythema, or function damage to an organ or physiological system.
- A dose to the embryo or fetus of a known pregnant patient that exceeds the specified dose threshold established by the Commissioner of Public Health, except when a dose to the embryo or fetus was approved by the ordering physician.
- Therapeutic ionizing irradiation to the wrong person or wrong site when total dose delivered differs 20% from the prescribed dose.
- Therapeutic ionizing radiation dose is more than 20% of the prescribed area.
- The Commissioner of Public Health shall provide specified dose values to the CTDPH during an incident.
- A healthcare provider shall report all radiation dose incidents to the patient within 15 days of the incident.
Compliance for Connecticut healthcare providers means routine management (review, analysis, and acknowledgement) of the patient imaging dose values and ionizing radiation device dose output . This may require an individual or team constantly monitoring patient and device dose information. Radiologist workflows will need to be updated, incorporating the recording of dose information generated from the CT scanner for all imaging exams. Healthcare providers will need to implement a process for managing radiation risks and communicating incidents of overexposure to the Commissioner of Public Health, the referring physician, and the patient.
The upcoming mandate also sets the stage for proactive healthcare providers in Connecticut to be industry leaders in radiation safety. Healthcare providers who want to gain an edge will need to go beyond the minimal requirements of the mandate and develop a radiation safety program, incorporating defined policies and procedures for all individuals involved in managing patient radiation dose compliance. ALARA (as low as reasonably achievable) radiation safety program workflows should be updated for all staff members responsible for managing patient radiation dose safety and should include a number of radiation incident management processes and proactive patient safety decision points to minimize radiation overexposure incidents. All imaging protocols should be reviewed and standardized, staff should be educated on good radiation dose imaging practices. Finally, healthcare providers should be ready to answer patient radiation dose concerns and educate their patients on the organization’s radiation dose safety practices so they understand that it is their mission to go above and beyond the mandate.
As Connecticut prepares for the upcoming patient radiation safety mandate, other states should prepare for a similar legislation. All healthcare providers should proactively evaluate their existing internal radiation safety program and processes and use the data to prepare for any upcoming radiation safety requirements. Expanded programs can be benchmarked against the new industry standard set by the American Association of Physicists in Medicine (AAPM) and adopted by the American College of Radiology (ACR).
Neil Singh is a consultant at Ascendian Healthcare Consulting and a frequent speaker and thought leader on Enterprise Dose Management. If you have questions you can contact Neil via email firstname.lastname@example.org.