Background

I am a medical imaging technologist working in western Washington. I am interested in bringing a lawsuit as an anonymous whistleblower against my employer concerning two potential legal violations in my workplace. Specifically, these violations relate to the processes used in writing and finalizing the interpretations of our medical imaging exams. Following are descriptions of each.

Potential Legal Violation #1

The first potential legal violation is both straightforward and readily provable. Imaging technologists have been instructed by management to write the physician interpretations on behalf of the reading physicians, without any input from those physicians at any point in the process. I have been informed by multiple sources that it is unlawful for imaging technologists to interpret the findings of an imaging exam and that doing so would constitute a violation of the False Claims Act (FCA). I have not verified this with any state or federal governments.

Here is our report writing process. The image below is a recreation of our report writing software interface. It displays three sections labeled Examination Findings (1), Technologist Impressions (2), and Physician Summary (3).

The Examination Findings and Technologist Impressions are written by the technologist. It is within the technologist's legal scope of practice to complete the Examination Findings, which describe what is visually observed in the exam images — without interpretation of disease processes or abnormalities. The Technologist Impressions section, however, is problematic. This section does not appear to be part of the software’s default layout but was reportedly added by management at our imaging lab. In this section, the technologist writes the physician's interpretation. The final section, Physician Summary (3), is where the reading physician is supposed to document their final interpretation of the exam. However, because the imaging technologists are writing the interpretations, the physicians use a shortcut. By clicking a link labeled "Copy to Summary" in the Technologist Impressions section (2), the physician automatically copies what the technologist has written from section 2 into the Interpretation field of the Physician Summary section (3). Below is a very short video demonstrating the actual process.

I should note that, as of August 2025, when a finalized exam is opened in the report-writing software, both the Sonographer Impressions and the Physician’s Impression (as shown in the referenced video) are visible to the reviewer. This information is locked once the exam is finalized and cannot be changed. I have personally reviewed several dozen exams that I authored in the past and have found no differences between the Sonographer Impressions and the Physician’s final interpretation. If a federal agency charged with investigating this matter determines that imaging technologists writing final physician interpretations constitutes an unlawful practice, and that the penalties for such activity are substantial, I would be prepared to move forward with a whistleblower action based solely on this information. Last year alone, my employer performed more than twenty thousand imaging exams with likely all of the interpretations being written by the imaging technologists. That said, I have also included below additional information concerning a separate potential violation of the False Claims Act.

Potential Legal Violation #2

The second potential legal violation stems from the first. As technologists, we can observe the studies being read almost in real time in our report writing software. Each study has an icon that changes when the report status updates from 'unread' to 'finalized.' Based on how quickly some reading physicians finalize their reports, I believe they are not always reviewing the exam images. Since the interpretation has already been written by the technologists, the physicians do not need to view the images themselves. I’ve been informed the reporting software we use (Epic Systems Corporation - Verona Wisconsin) is capable of tracking whether the images were viewed—and for how long—but I am unable to confirm this.

I have observed errors made by technologists in writing the physician’s interpretation that are carried over uncorrected from the Technologist Impressions section to the Physician Summary. On two occasions, I have seen studies finalized by the reading physician that contained no attached exam images. I have also seen the same interpretation text duplicated in the final report, suggesting that the reading physician clicked the “Copy to Summary” link in the Technologist Impressions section more than once and did not notice the text was duplicated in the Physicians Interpretation.

Career Ending Decision

If I decide to proceed as an anonymous whistleblower, I recognize that it is unlikely I will be able to find work again in medical imaging. As an older technologist, securing employment in this field at my age is already extremely difficult if not impossible. For this reason, I would like to pursue a whistleblower reward that could replace my income and cover health insurance costs for at least five years.