Lake Medical Imaging and Breast Center at The Villages

Joshua L. Floyd

Patient Safety Advocate

My motto during my entire healthcare risk management career has always been, What is best for the patient? My goal is continuous improvement, yet I have witnessed a critical gap that remains largely unaddressed in our healthcare system. Even in the most advanced technological age that we are in, patients still fall through the cracks every single day. Millions of patients receive imaging studies each year, yet the United States has zero federal mandate requiring healthcare organizations to manage incidental findings or ensure recommended follow-up occurs.

No such requirement exists to make sure you know about a finding in your own body once you leave the facility. This regulatory void represents one of the most significant overlooked risks in healthcare quality, patient safety and medical liability. My plan is to solve this problem and change healthcare forever.

Incidental findings are unexpected abnormalities discovered during diagnostic imaging that are unrelated to the patient’s presenting complaint but may require additional evaluation. Examples include pulmonary nodules, renal masses, aneurysms, or adrenal lesions. Although these findings are often documented by radiologists with recommendations for followup, responsibility for ensuring those recommendations are communicated and completed frequently becomes fragmented among radiologists, referring providers, hospitals, outpatient imaging centers and patients themselves.

The absence of standardized accountability has become increasingly problematic as imaging volumes continue to rise. Annual CT examinations have increased from approximately three million studies in 1980 to more than 90 million today, while individual examinations now contain thousands of images instead of dozens. Consequently, incidental findings have increased, occurring in nearly one-quarter of imaging examinations and approximately one-third of CT studies. Yet research consistently demonstrates that a large percentage of recommended followup imaging is never completed or even communicated.

Communication failures remain among the leading causes of adverse events in healthcare and represent one of the fastestgrowing categories of medical malpractice involving radiology. Courts have increasingly held that simply sending a radiology report may not satisfy the standard of care when clinical findings require additional evaluation. Healthcare organizations face increasing legal exposure without a standardized national framework to guide compliance.

Numerous federal agencies already regulate adjacent aspects of healthcare quality. The Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services (HHS), the Agency for Healthcare Research and Quality (AHRQ) and accrediting organizations such as The Joint Commission establish performance expectations for patient safety, quality reporting and communication processes. Similarly, the American College of Radiology provides voluntary guidance regarding incidental findings. However, none require organizations to implement a comprehensive system.

This gap represents an opportunity for thoughtful federal policy rather than additional regulatory burden. Unlike many policies, this will have an immediate and direct impact on patient safety.

Recent advances in artificial intelligence demonstrate that comprehensive incidental finding management can now be accomplished with minimal disruption to workflow. Modern AI platforms can automatically analyze radiology reports using natural language processing, identify actionable recommendations, classify findings by urgency, notify referring providers, generate patient communications and create auditable documentation of every communication attempt. Importantly, these systems function as safety nets without requiring radiologists to perform additional manual tasks.

The operational benefits extend beyond patient safety. Automated incidental finding programs reduce communication failures, improve care coordination, strengthen documentation for malpractice defense and increase adherence to recommended follow-up imaging. For healthcare executives operating within increasingly value-based reimbursement environments, these programs simultaneously improve quality metrics, reduce organizational risk and support sustainable revenue growth.

Real-world implementation further supports this approach. Following implementation of an AI-assisted incidental finding management program, our outpatient radiology organization processed more than 1.7 million radiology reports, identified over 339,000 imaging recommendations, generated nearly 130,000 patient notification letters and reported zero failure-tocommunicate malpractice claims during the observation period. While individual organizational outcomes will vary, these results illustrate that management of incidental findings is operationally achievable at scale when supported by technology and standardized processes.

A federal mandate should not require a single approach. Instead, policymakers should establish minimum performance standards requiring healthcare organizations performing diagnostic imaging to demonstrate four core capabilities: automated identification of actionable incidental findings, documented communication with responsible clinicians and patients, tracking of follow-up recommendations until clinical resolution or documented patient refusal and auditable reporting for regulatory review. Such standards would allow flexibility in selecting technology solutions that best integrate with their existing clinical workflows.

Healthcare has successfully implemented national standards for infection prevention, medication safety and even patient satisfaction reporting. Hospitals are required to call patients and ask them how clean their room is but not required to call you about the nodule they found in your lung! Incidental finding management deserves similar attention. Every delayed cancer diagnosis or missed follow-up recommendation represents not only a potential malpractice claim but also a preventable poor outcome for the patient.

The technology exists. The clinical evidence continues to grow. The operational models have demonstrated success. What remains absent is national leadership. I believe that establishing a federal mandate for incidental finding management would create consistent expectations across healthcare organizations, reduce preventable patient harm, strengthen accountability and help ensure that clinically significant findings no longer disappear. That is what is best for the patient. Closing this loop has the potential to become one of the most significant patient safety advancements in modern healthcare.