Pa. law rewrites rules on patient notification

By Rebecca Farrington, contributing writer

October 30, 2019 -- A Pennsylvania law going into effect in December will rewrite the rules on when patients should be notified about abnormalities detected on their imaging exams.

The Patient Test Result Information Act, or Pennsylvania Act 112 of 2018, will take full effect on December 23, 2019.

Rebecca Farrington
Rebecca Farrington from Healthcare Administrative Partners.

The act was originally scheduled to begin in December 2018, but the imposition of citations and fines was delayed for one year. During that time, many hospitals and radiology practices have implemented systems designed to help them comply with this law.

To review, this act provides that the patient must be directly notified within 20 days when a diagnostic imaging exam is performed that identifies a "significant abnormality" may exist. The law defines a significant abnormality as one that "would cause a reasonably prudent person to seek additional or follow-up medical care within three months."

It is important to note that this notice to the patient is in addition to the normal reporting of results to the ordering physician. A full detailed explanation of the rules to comply with this Pennsylvania state law is available in our December 2018 article.

A group of radiologists from the Hospital of the University of Pennsylvania and Pennsylvania Hospital led by Dr. Gregory Mittl published a case study, titled "Ensuring Patient Follow-up of Significant Abnormalities Under Pennsylvania Act 112," in the Journal of the American College of Radiology (September 28, 2019). They described in detail a variety of methods used by their colleagues in various hospitals to capture the information needed to trigger notification under the act, summarized as follows:

Events that could trigger patient notification
Triggering event Action taken
Hard stop: Radiologists are required to indicate within the dictation software whether a patient notification is needed. A daily structured query language report generates a list of patients for whom notification letters are needed.
A sentence is automatically inserted at the bottom of the report, from which an automated patient letter is generated.
Voluntary: Radiologists insert standardized language to flag patients who should be notified. There is no system prompt. A natural language processing algorithm is employed to search for signed reports with key words such as "recommend" or "follow-up."
An existing provider notification system was modified whereby reading room coordinators communicate critical and significant results for all patients designated by radiologists in the dictation software and electronic health record. The coordinator fills in the required patient and examination information into a patient notification letter template designed to comply with Act 112.

Some hospitals include the reporting of nonradiologist readers in their systems even though the Pennsylvania Department of Health has not provided clear guidance as to which diagnostic services outside of radiology are covered under the act. The act specifies that the requirement to notify the patient does not apply to the following:

  • Routine obstetrical ultrasound exams
  • Plain x-rays
  • Emergency department imaging services
  • Inpatient imaging services

Most practices have adopted an "embargo period" of three to 10 days after the report is signed before sending out the patient notice so that ordering providers have time to review and discuss the results directly with patients, according to the case study.

"Pennsylvania Act 112 represents a paradigm shift in communication of abnormal diagnostic imaging findings directly to patients," the authors concluded.

The need for such a paradigm shift was highlighted in our review of the lessons learned from a $10 million award in a medical malpractice lawsuit that might not have occurred had this law been in effect in 2015.

We have described such a paradigm shift in several articles about our own system, which uses clinical analytics to identify incidental findings recommended for follow-up, notifies the patient about the situation, and then tracks their compliance with the recommendation. That same system was modified at the request of our Pennsylvania clients to comply with Pennsylvania Act 112 requirements.

Rebecca Farrington serves as the chief revenue officer for Healthcare Administrative Partners. She has more than 20 years of experience in healthcare sales and management roles, focusing on hospital-based and physician revenue cycle management.

The comments and observations expressed are those of the author and do not necessarily reflect the opinions of

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