Re: Authorized user vs Interpreter

[carol marcus <csmarcus@ucla.edu>]

At 09:34 AM 5/4/99 -0500, you wrote:
>Most recently, the State of Ohio and confirmed by the NRC,  has determined 
>that the interpretation of nuclear medicine scans does not fall under the 
>requirements of an "authorized user".  Is this a common interpretation 
>amongst the agreement states?  How have the hospitals handled this 
>situation?  
>This has a significant impact for Cardiologist and Internal Medicine 
>physicians who want to interpret there own work, and bill for it, and are 
>not the "authorized user" at a given location.  
>
>REGARDS
>
>dan
>
>
>
>DAN L. MARX
>dmarx01@baker.edu
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>
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Dear Radsafers:

While NRC does not regulate who writes Nuclear Medicine reports, that does
not mean that Authorized User Physicians do not need to write them.  Other
groups expect AUP's to write reports; this is the standard of medical
practice. It is hard for me to imagine how any hospital or healthcare
organization would give practice privileges to a physician to practice
Nuclear Medicine UNLESS that physician produced reports. It is also
impossible to write a competent report of a Nuclear Medicine procedure
unless the physician is qualified to practice Nuclear Medicine and is
familiar with and knowledgible about the technique used by the Nuclear
Medicine technologist.  

I don't think that Ohio Rad Health should make any requirements about
report-writing; this is well beyond the competence and mandate of this
Agency.  However, Ohio Rad Health ought to ask the Ohio Board of Medicine,
the JCAHO, the Society of Nuclear Medicine, and the American College of
Nuclear Physicians for their opinions as to whether the writing of reports
by AUP's constitutes the standard of medical practice and is necessary for
medical quality for JCAHO accreditation. I think that the answer would be
"yes" in all cases.

In addition to this, I think that it would be illegal for a non-AUP to order
a Nuclear Medicine procedure only from someone who would let the referring
physician non-AUP interpret it and bill for it.  That is both fee-splitting
and  self-referral, and both of them are illegal.

In California, the Radiologic Health Branch is part of the Department of
Health Services, and some medical quality obligation is therefore imposed
upon RHB.  RHB expects an AUP to write a report, but does not go any
further, which would be the jurisdiction of the Medical Board of California.

Ciao, Carol

Carol S. Marcus, Ph.D., M.D.
<csmarcus@ucla.edu>

(310)222-2845

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