Eighty percent of unregulated pregnancy clinics (UPCs) offer obstetric ultrasound examinations. That procedure requires supervision by a doctor. But in many or most cases, supervision isn’t happening.
An obstetric ultrasound examination requires an order from a doctor or other similarly-qualified licensed medical provider, like a nurse practitioner. Often, ultrasounds operate under procedures designated in a doctor’s “standing order.”
In addition, as the AIUM (the association for medical ultrasound) explains:
Ultrasound studies shall be supervised and interpreted by a licensed medical provider who meets the training guidelines in the specific area of sonography. Findings must be recorded and results communicated in compliance with the AIUM Practice Parameter for Documentation of an Ultrasound Examination. Although a sonographer may play a critical role in extracting the information essential to formulating a diagnosis, the rendering of the final diagnosis of ultrasound studies represents the practice of medicine, and, therefore, is the responsibility of the supervising licensed medical provider.
So, an obstetric ultrasound requires a doctor’s supervision both before and after the technician performs a scan. And the technician has no business ordering or interpreting an ultrasound scan; that can only be done by a doctor or other similarly-qualified provider.
Are doctors actually supervising these procedures?
According to the Lozier Institute, which is a nationwide policy center for UPCs, in 2022 there were 2,248 UPCs with ultrasound machines which performed 546,683 examinations. Considering that UPC doctors are overwhelmingly off-site volunteers, it is hard to believe that all those ultrasound scans are supervised and reviewed in a timely and professional manner by doctors acting within their scope of practice. These off-site volunteer doctors actually practice medicine somewhere else. It certainly seems like a lot of UPC “medical directors” are simply allowing their names to be used as a favor.
How is a state department of health supposed to ensure that these medical procedures are performed in a professionally responsible manner? The state doesn’t even know who the UPC medical providers are. Similarly, UPC clients see licensed or unlicensed nurses and technicians, but they don’t see any doctor. How do they even know who their supervising doctor is?
States need to require that: (1) UPCs which offer medical care in general, and ultrasound exams in particular, must have real, responsible medical supervision; (2) UPCs disclose to the state department of health who is taking responsibility as the supervising doctor(s); and (3) UPCs provide clients, upon request, the contact information for their supervising doctor(s).
The Society for Adolescent Health and Medicine and the North American Society for Pediatric and Adolescent Gynecology jointly stated support for this policy position: “[We] urge all governmental, regulatory (e.g., medical and nursing boards), and accrediting bodies with responsibility for enforcing medical and ethical practice standards to ensure that health care professionals providing services at CPCs and services delivered at CPCs adhere to established standards of care.” Similarly, the American Medical Association “urges the development of effective oversight for entities offering pregnancy-related health services and counseling.”
These are very modest requirements for any state to impose.