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Today, AB 460 comes before the California Senate Committee on Health, aiming to modernize supervision rules for contrast-enhanced X-ray and CT procedures. While MRI contrast injections are already permitted with remote physician oversight under current federal and state frameworks, California still requires a physician to be physically on-site for radiologic technologists (RTs) administering contrast for X-ray and CT exams.
This outdated requirement contributes to delays, unequal access, and workforce bottlenecks — especially in rural and underserved communities — even as secure, real-time audiovisual technology is widely available.
Tether Supervision supports AB 460 as a balanced, patient-focused bill to bring California in line with CMS and other states. However, we encourage one important clarification on electronic medical record (EMR) requirements, described below.
Background and Legislative Analysis
Current Law and Its Challenges
Under existing California law, RTs performing venipuncture to inject contrast agents for X-ray or CT must do so under the physical on-site presence of a licensed physician, defined as “direct supervision.” This policy was created before modern, secure video communication made virtual supervision practical and safe.
By contrast, federal CMS policy — and California practice for MRI procedures — already allows remote supervision through real-time audio-video communication. Extending this flexibility to X-ray and CT contrast injections is long overdue.
Problems with the current policy include:
- Limited access to radiologist supervision, especially after hours or in rural areas
- Procedure delays from physician shortages
- Compliance gaps that risk accreditation or patient safety
- Barriers to innovation in outpatient care
What AB 460 Would Do
AB 460 proposes to expand the definition of direct supervision to include real-time audio and video communication, with the physician immediately available to intervene through standing orders or protocols. Facilities would still be required to:
- Maintain robust safety protocols
- Have qualified personnel on-site to manage emergencies
- Ensure proper documentation under physician direction
Importantly, MRI contrast injections already fall under federal and state policies that permit virtual supervision, demonstrating that such oversight is clinically safe and practical. AB 460 simply extends the same modern framework to X-ray and CT-based contrast procedures, keeping California consistent with national standards.
Tether Supervision’s Position on AB 460
Tether Supervision strongly supports AB 460 because it:
- Aligns with CMS policy that has proven safe since 2020
- Expands patient access to timely imaging
- Supports imaging center efficiency statewide
- Retains critical safeguards to protect patients
However, in our formal support letter, we offered a clarification about EMR access. The current bill language may imply that supervising physicians must have full EMR access at all times. Tether is concerned this could:
- Create expensive technical hurdles for small or rural centers
- Increase cybersecurity risks
- Undermine AB 460’s goal of equitable, flexible access
Instead, we recommends allowing on-site staff to communicate all necessary patient screening and clinical information to the supervising physician, without requiring full EMR integration. This ensures remote oversight is both safe and practical, without excluding smaller or independent facilities.
Actionable Takeaways for Healthcare Facilities
Imaging center leaders can prepare for AB 460 by:
- Reviewing existing contrast supervision policies
- Training technologists on remote collaboration with supervising physicians
- Verifying safety protocols and emergency response capabilities
- Setting up secure, HIPAA-compliant audio/video systems
- Discussing EMR and documentation workflows with supervising radiologists
With these steps, facilities can confidently adopt remote supervision models that improve throughput, reduce wait times, and maintain compliance with ACR and CMS guidelines.
Conclusion
AB 460 represents a timely, practical, and clinically proven update to California’s supervision laws. Virtual oversight has already demonstrated safety and effectiveness for MRI contrast injections; it is only logical to extend these benefits to X-ray and CT contrast procedures.
As the bill advances in the Senate Health Committee today, Tether Supervision urges lawmakers to adopt this much-needed reform with the clarifying change around EMR requirements — ensuring California supports safe, equitable, and efficient imaging services for all communities.
Learn more about Tether Supervision’s services here or contact us to explore how virtual supervision can work for your facility.
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