Be prepared—new Joint Commission requirements effective July 1

After a long delay, the Joint Commission’s revised requirements for diagnostic imaging services go into effect on July 1, with significant dose-management implications for providers of CT. The requirements, first announced in January, apply to all accredited organizations that provide diagnostic imaging services.

The Joint Commission (JC) first announced its revised requirements for diagnostic imaging services in December 2013, which came after a long period of research and analysis. After the announcement, however, feedback from various accredited customers and professional organizations prompted the organization to step on the brakes.

Andrea Browne, a medical physicist who works in the commission’s department of engineering, said that the JC talked to “everybody” again, including the American Board of Radiology, the ACR, the Nuclear Medicine Technology Certification Board and other relevant organizations.

“We decided to pull those revised requirements and take a good, hard look at them again,” she said. “As a result, there were two that we deleted and then we made some modifications to some others.”

The standards were released in January 2015, and as a result, dozens of revised requirements will go into effect on July 1, covering various aspects of diagnostic imaging, with implications for all advanced modalities and a host of new dose-management protocols with which to comply.

Radiologists and technologists will need to familiarize themselves with all of the requirements, but Browne listed some that are especially important to learn about in great detail. Those requirements include:

• A patient’s CT radiation dose index must be recorded and made available in a retrievable format. When the updated standards were originally proposed in 2014, the Joint Commission said the CT dose index must be inserted into the patient’s interpretive report. Feedback from radiologists and others led the commission to change that requirement.
• Various parameters must be verified prior to imaging. Before you conduct an imaging study, you have to verify that you have the correct patient, that you’re going to image the correct part of the patient, that you’re positioning the patient correctly. For CT, verify that all technical factors you choose are appropriate, and that you have it set up on your scanner correctly. Browne pointed out that this process should already be standard practice, but it’s something surveyors will be closely watching. “Organizations are looking at, ‘How do I meet that?’” Browne said. “Well, you’ve got to look at your intake processes, and that’s what the surveyor will do, that’s how they will judge this. They’ll watch what they do when they bring a patient into the CT department to do a study. They’ll look to see, ‘are they considering these things when they set it up?’’’
• Organizations must adopt or create protocols that include how much radiation patients are expected to be exposed to for each CT imaging exam. If it is discovered that a particular CT study exceeded predetermined radiation limits, it must be properly investigated.
• CT test standards must be periodically reviewed. After selecting CT protocols (see the previous requirement), that information must be reviewed regularly to confirm patients are being exposed to the minimal amount of radiation required to do a good study.“We want you to think about it,” Browne said. “The words they use are ‘radiation dose optimization,’ meaning you use the minimal amount to do an interpretive or good study. It’s not just ‘low dose,’ it’s ‘dose optimization.’”The patient’s age and prior imaging history must be considered. The protocol used for a scan must be modified based on the size and age of the patient. Also, recent medical history must be looked at avoid unnecessarily repeating scans.

A full list of the revised requirements for diagnostic imaging services is available online.

Frequently asked questions

Browne noted that many physicians and organizations seem to have the same basic questions about these requirements.

For instance, many are reaching out to the JC about any requirement that involves tests or reviews being performed annually. Individuals are asking if all of those tests and reviews need to be performed by July 1, but Browne said she assures them that is not the case. In those instances, organizations will have a full year —until July 1, 2016—to perform those actions.

The commission is also asked frequently about a requirement related to structural radiation shielding.  

“The new requirement says that before you do any construction or new equipment installation or you modify an area where there’s ionizing radiation (CT, nuclear medicine or PET), you have an evaluation performed by a medical physicist,” Browne said. “And after the construction is completed, there is a survey conducted to show that the amount of shielding, if it was required, was adequate.”

Browne said many organizations feared that this was a retroactive requirement, but that is not the case. It is only for modifications made after July 1.

Browne also said that the commission continues to welcome questions and feedback. Providers are encouraged to reach out. The JC wants to get the requirements right and will continue revising them as necessary.

“We want to make the best decisions,” Browne said.