Background

I am a healthcare worker currently employed in western Washington. I am interested in bringing a lawsuit as an anonymous whistleblower against my employer concerning two potential legal violations which I have directly observed. Specifically, these violations relate to the processes used in writing and finalizing the interpretations of 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 the report writing process in question. The image below is a recreation of the 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 imaging 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. 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).

I should note that, as of October 2025, when a finalized exam is opened in the report-writing software, both the Sonographer Impressions and the Physician Interpretation are visible. Anyone investigating this matter can easily compare what the technologist has written to the Physician’s Interpretation. This information is locked once the exam is finalized and cannot be changed unless the exam is unloced by the reading physician.

When an imaging technologist writes the physician’s interpretation, the technologist may either rely on pre-written statements for their impression or compose the impression entirely freehand, depending on the type of exam and the findings. In cases where the impression is written freehand and contains detailed information, it becomes clear that the technologist has authored the physician’s interpretation for the reading physician, as the technologist’s impression almost always matches the physician’s interpretation exactly.

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, the employer in question performed more than twenty thousand imaging exams, with likely all of the interpretations written by imaging technologists. This activity has been occurring since 2012 with an estimated 200,000 exams performed over those years. 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. The imaging technologists can observe imaging studies being read almost in real time in the report writing software. Each study has a related icon that changes from a red circle to a green checkmark when the report status updates from 'unread' to 'finalized.' Based on how quickly some reading physicians complete their reports, I believe they are not always reviewing the exam images. Since the interpretation has already been written by the imaing technologists, the physicians do not need to view the images themselves. I’ve been informed the reporting software used is capable of tracking whether the images were viewed — and for how long — but I am unable to confirm this.

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 in healthcare. As an older employee, securing employment in my field 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.