Sheila - We updated our policy in January for same concerns. Consulted our malpractice carrier for guidance.
Always an issue.
CURBSIDE CONSULTS & INTERPRETATION OUTSIDE EXAMS - Final
Revised 1-7-20
Formal Interpretation Outside Film/Exam (OSF):
Objective: Provide formal interpretation on an exam that has been performed at another location and interpreted elsewhere, whether or not prior report is available. By definition, this is a documented radiologist-patient relationship.
Examples:
- "Quick" review of OSF for fracture or PNA.
- Review of case CT/MRI/PET which is complex or time-consuming.
- Review of OSF where referent questions/disagrees with outside interpretation.
- Review of prior exam where obtaining outside report is not possible but is needed.
- Review of exams at subspecialty Case Conferences
Standard Procedure:
- Every attempt should be made to obtain OSF report, and this service should not be provided as a substitute for standard process of obtaining prior records.
- OSF interpretation requires a formal request by referring clinician. The clinician should specify reason OSF interpretation is required (disagree with original interpretation, unable to obtain prior report, etc).
- This workflow is in place in Epic and PACS. E.g. for head CT, the order is "CT Head Outside Interpretation." This will automatically be placed into PACS with accession number for dictation, in Complete status. If exam is older than several months, it could be excluded from the worklist by filter constraints, and in that case the tech should verbally notify the radiologist.
Billing Notes: Patient will be billed for OSF interpretation. ER patients sign consent for care, thus no separate consent is needed for this read. For outpatients, the workflow is more complex, involving more legwork in advance of interpretation. A pre-authorization may be required in the case of CT or MR, depending on insurance. If Medicare, patient may need to sign ABN. Plain films may be presented to radiologist to assess quality (may not be sufficient to warrant an interpretation).
Special Cases
- Request for Addendum on Exam Interpreted by another Vantage Radiologist: If possible, refer the requesting provider to the original radiologist. If not possible, dictate addendum and any communication with requesting provider, notify original radiologist, and submit PR Disagree if applicable.
- Review of OSF as comparison to in-house exam: Use standard dictation procedure. Formal OSF interpretation request not required.
Informal (Curbside) Consult or Outside Exam Review:
Objective: Address a non‐patient-specific question/situation/scenario that provides general academic advice for the benefit of the referring physician. There is no established or documented patient-radiologist relationship.
Note: Traditionally, medical malpractice liability for curbside consultations has hinged on an established physician‐patient relationship. If the consulting physician directs care (e.g., recommends further test, films, identifies anomalies, etc.), almost certainly it will be viewed as an establishment of a professional relationship with all the attendant obligations and accompanying liability risks.
Examples:
- Discussing what type of radiology exam to order for a specific clinical scenario
- Providing detail about policy re: contrast reaction management
As standard procedure:
- Have low threshold for requesting formal consultation as things get patient-specific or complex. It would be exceedingly difficult to provide an informal consult for a specific exam in PACS.
- The radiologist should ask the referent to avoid putting your/our name in patient record.
- The referent should understand that this is a courtesy service for which we are not billing and it represents general, non-patient-specific advice.
- Avoid discussing the patient's name or medical details.
- Avoid making recommendations for treatment.
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Beth Williams MHA, FACMPE, FRBMA
Executive Director
Vantage Radiology and Diagnostic Services
Federal Way WA
(253) 661-1700 ext. 1105
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Original Message:
Sent: 07-21-2020 15:03
From: Sheila Witous
Subject: Second Opinions/Curbside Consults
I am looking for direction/guidance/your experience on 2 similar issues.
First, when a referring physician seeks a curbside consult on a study that has already been interpreted (usually by another one of our docs) some of my physicians think it puts them in legal jeopardy if they dictate the outcome of the consult. Their fear is that their name will now be in the medical records and they could be swept up in a malpractice claim if one is filed. I have always preached that we need to document, document, document. Adding their impression to the records protects against the referring physician inadvertently documenting the wrong conclusion in the medical records. What are your practices in this regard?
The second issue is when a patient is shipped to our facility and they have had studies taken elsewhere. The trauma physicians often look to us for a second opinion on these studies even though they were interpreted at the previous facility. Sometimes the reports don't follow, or the physician just wants to have the local team's impression. Some of our options are:
Interpret and don't charge.
Interpret and charge the patient's insurance, and ultimately the patient.
Interpret and charge the hospital for the qa overread.
Would love to hear your experiences in these matters and to get a feel for the "best practices".
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[Sheila] [Witous] [MBA, CPA, CGMA]
[Chief Administrative Officer]
[Radiology, Inc.]
[South Bend] [IN]
[(574) 258-1100 ext. 205]
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