Policy and Procedure (P&P) Template: Communication with Self-Referred Patients for Breast Imaging Procedures
Below is an example of a Policy and Procedure (P&P) Template that you can use as a foundation for your Breast Imaging Center's Policy Manual, particularly for policies related to FDA MQSA (Mammography Quality Standards Act) compliance. This specific example focuses on communicating with self-referred patients for breast imaging procedures such as mammograms. It is designed to ensure that self-referred patients receive the same level of communication, care, and follow-up as those referred by a healthcare provider while also addressing the unique considerations that apply to self-referred patients as prescribed within the FDA MQSA regulations.
Policy Name:
Communication with Self-Referred Patients for Breast Imaging Procedures
Effective Date:
[Insert date here]
Policy Number:
[Insert policy number here]
Review Date:
[Insert review date here]
Approved By:
[Insert name and title of approver here]
1. Purpose:
This policy establishes clear guidelines for communicating with self-referred patients undergoing breast imaging procedures such as mammograms at the Breast Imaging Center. It ensures that self-referred patients are informed of their rights, receive their mammography results in compliance with FDA MQSA (Mammography Quality Standards Act) regulations, and are guided in accessing follow-up care when needed.
2. Scope:
This policy applies to all patients who self-refer to breast imaging services at the Breast Imaging Center. It covers the process of patient communication before and after the procedure, including delivering mammography results, advising patients on follow-up care, and documenting communications.
3. Policy:
The Breast Imaging Center's policy is to ensure that all self-referred patients receive the same level of care and communication as patients referred by healthcare providers. Self-referred patients will be fully informed of their mammogram results in a timely manner, in compliance with MQSA requirements, and will be provided guidance on how to pursue any necessary follow-up care.
Key Points:
- Self-referred patients will be informed of their mammography results through lay letters that contain all required components, including the facility name, address, and contact information, and a clear explanation of the results.
- A copy of the radiologist's test results report typically dispatched to a healthcare provider-referred patient, will be mailed with the lay letter.
- Self-referred patients are responsible for seeking medical follow-up based on their results. The Breast Imaging Center will provide guidance on how to establish care with a primary healthcare provider or specialist if needed.
- All communications with self-referred patients, including the delivery of results and follow-up guidance, will be documented.
4. Definitions:
Self-Referred Patient: A patient who schedules and undergoes a mammogram or other breast imaging procedure without a referral from a primary care physician or specialist.
Lay Letter: A letter written in plain language that communicates mammography results to the patient.
MQSA: The Mammography Quality Standards Act, a federal law that sets national standards for mammography services and requires that patients receive clear and timely communication of their results.
5. Procedures:
5.1 Pre-Procedure Communication
- Patient Consent and Education: Before the procedure, the self-referred patient must sign a consent form acknowledging that they are self-referred. The form should explain:
- The nature of the self-referral.
- The responsibility of the patient is to seek medical follow-up based on their results.
- The center’s role in providing results not ongoing treatment.
- The procedure for obtaining results and any follow-up steps.
- Patient Information: The Breast Imaging Center staff will inform self-referred patients about the importance of sharing their results with a healthcare provider for continued breast health management, especially if further diagnostic work is needed.
5.2 Lay Letter Communication
- Content Requirements: The lay letter sent to self-referred patients will contain:
- The name of the facility, address, and telephone number.
- A clear explanation of the mammography results in lay language.
- Specific follow-up recommendations based on the result (e.g., routine screening in one year, additional diagnostic imaging, or referral to a specialist).
- A statement advising the patient to contact a healthcare provider for further evaluation, especially if the results are abnormal.
- Timing of Lay Letter Delivery:
- Negative/Benign Results: Lay letters must be sent within 30 days of the mammogram.
- Abnormal Results: For patients with suspicious findings, lay letters must be sent within 7 days. The Breast Center will also make a reasonable effort to contact the patient by phone to ensure they receive their results promptly.
5.3 Follow-Up Guidance for Self-Referred Patients
- Routine Follow-Up: For self-referred patients with normal results, the lay letter will recommend routine annual screenings and advise the patient to share the results with their primary care provider.
- Abnormal Results: For patients with suspicious or abnormal results, the lay letter and phone communication will include:
- A clear description of the abnormality.
- Recommendations for further diagnostic testing (e.g., additional mammogram views, ultrasound, biopsy).
- Strong encouragement for the patient to consult a healthcare provider or specialist for follow-up care.
- If the patient does not have a provider, the Breast Imaging Center will offer assistance in identifying local healthcare providers or specialists.
- Patient Responsibility: While the Breast Imaging Center will communicate the results and provide follow-up recommendations, the patient is responsible for pursuing follow-up care.
5.4 Documentation
- Patient Records: All communications, including the mailing of lay letters, phone calls, and any assistance provided to the patient in seeking follow-up care, will be documented.
- Tracking Delivery:
- A record of the lay letter, including a copy of the letter itself.
- Documentation should include proof of production and mailing via a letter tracking number.
- In cases where a letter is undeliverable, reasonable attempts will be made to contact the patient via phone or other methods, and these attempts must also be documented.
6. Responsibilities:
Patient Navigator/Coordinator: A designated staff member (e.g., patient navigator or coordinator) will be responsible for overseeing communications with self-referred patients, including ensuring that results are delivered in a timely manner and that the patient is provided with resources for follow-up care if needed.
Administrative Staff: The administrative team is responsible for preparing, sending, and documenting the delivery of lay letters to self-referred patients.
Medical Director/Radiologist: The interpreting radiologist or Medical Director will review any letters associated with abnormal findings to ensure clarity and accuracy before they are sent to the patient.
7. Quality Assurance:
Audit of Self-Referred Patient Communication: Regular audits will be conducted to ensure that communications with self-referred patients are timely, compliant with MQSA regulations, and properly documented.
Patient Feedback: Self-referred patients may be surveyed for feedback on the clarity and usefulness of the lay letter and follow-up recommendations.
8. Training and Education:
- All staff involved in the management and communication of results to self-referred patients will receive training on:
- The specific needs and responsibilities associated with self-referred patients.
- MQSA requirements for patient communication.
- Procedures for documenting communications and follow-up assistance.
9. Patient Privacy and HIPAA Compliance:
All communication with self-referred patients, including lay letters and follow-up calls, will comply with HIPAA regulations to ensure the confidentiality of patient information.
10. References:
FDA MQSA Guidelines: [Link to relevant FDA guidelines]
HIPAA Regulations: [Link to relevant HIPAA information]
11. Related Policies:
Policy on HIPAA Compliance and Patient Privacy
Policy on Breast Density Notification
Policy on Mammography Result Communication
12. Appendices:
Appendix A: Example Lay Letter for Self-Referred Patient (Normal Results)
Appendix B: Example Lay Letter for Self-Referred Patient (Abnormal Results)
Appendix C: Consent Form for Self-Referred Patients
Review and Update History:
[Insert dates of past reviews and updates]