In a significant development for radiology services in California, Governor Gavin Newsom has signed Assembly Bill No. 460 (AB 460) into law, easing long-standing restrictions on the supervision of radiologic technologists during the administration of contrast media.

The bill allows certified technologists to administer contrast agents under remote supervision, marking a practical shift in the delivery of imaging services. This is particularly relevant in outpatient, rural or after-hours settings where on-site physician presence may be limited. For hospitals, imaging centers and compliance professionals, this change introduces new opportunities to rethink workflows and address staffing challenges. At the same time, it raises important questions about maintaining safety and regulatory compliance.

Easing the Supervision Requirement for Contrast Administration

Prior to this legislative change, California law required that radiologic technologists perform contrast injections only under the immediate, in-person supervision of a licensed physician and surgeon. This created operational challenges, particularly in outpatient and rural settings where on-site supervision wasn’t always feasible.

AB 460 updates Health and Safety Code §106985 (HSC §106985) to allow for remote supervision in specific circumstances. The law permits radiologic technologists and technicians to perform venipuncture in an upper extremity for the purpose of injecting contrast media, under a revised definition of “direct supervision.” Under the new law, “direct supervision” means a licensed physician and surgeon is either:

  • Physically present within the facility and immediately available to intervene, or
  • Available immediately via audio and video communication, with access to the patient’s imaging records and the ability to intervene by directing on-site personnel.

This change represents a significant departure from the prior physical presence requirement. It opens the door to more flexible and scalable imaging workflows, provided that facilities implement appropriate remote communication protocols and support structures.

Practical Impact for Healthcare Providers

The most immediate effect of the changes to HSC §106985 is operational. Facilities that provide contrast-enhanced imaging, such as CT and MRI, now have greater flexibility in how they schedule and staff these procedures. This may be especially beneficial for rural hospitals, outpatient centers and after-hours imaging operations, where having a supervising physician physically present has often posed logistical challenges.

That said, providers must take steps to ensure that they implement remote supervision safely, effectively and in accordance with regulatory requirements. Key considerations include:

  • Assessing supervision structures: Determine which clinical scenarios are appropriate for remote supervision and whether existing workflows need to be redesigned.
  • Establishing reliable communication protocols: Supervising physicians must be available via audio and video without delay. Facilities should evaluate what platforms and processes meet this standard and ensure backups are in place.
  • Training and competency validation: Radiologic technologists must complete proper training and obtain certification to perform venipuncture and administer contrast under remote supervision. As amended, HSC §106985 requires technologists to complete at least ten (10) hours of supervised instruction and to perform ten (10) venipunctures in an upper extremity, either on a human subject or a simulation device such as an infusion arm or mannequin arm, under personal supervision. Facilities should update their training protocols and maintain documentation demonstrating satisfaction of these requirements.
  • Emergency response procedures: If a patient has an adverse reaction to contrast, technologists need clear protocols and immediate access to on-site support. Remote supervisors should also be ready to direct the response as needed.

Legal and Compliance Considerations

From a legal standpoint, the standard of care remains unchanged, but the model of supervision has evolved. With that evolution comes potential exposure if organizations do not align their policies and practices with the statute.

Rolling out new supervision models without adequate legal review could lead to misalignment with state or federal requirements. Legal and compliance teams should get involved early to assess policy gaps, update procedures and ensure that flexibility under HSC §106985 does not conflict with existing reimbursement or oversight rules.

Other key compliance issues include:

  • Clarifying what “available immediately” means: Until the California Department of Public Health (CDPH) issues any further guidance, the statutory language leaves some room for interpretation. In the interim, providers should adopt conservative protocols that demonstrate real-time availability and responsiveness. For example, it would likely be problematic if the supervising provider is scheduled to perform patient procedures at the same time they are expected to be “available immediately” to provide remote supervision to technicians administering contrast.
  • Documenting supervision and communication: Facilities should maintain clear records of supervisory arrangements, including logs of who provided oversight, how they were contacted and what technologies the team used.
  • Coordinating with federal requirements: Providers participating in Medicare or Medicaid must ensure that remote supervision under HSC §106985 does not conflict with federal supervision standards for diagnostic imaging before making any operational changes.

Conclusion

The changes to HSC §106985 represent a meaningful shift in how providers can supervise contrast-enhanced imaging procedures in California. For healthcare organizations, it offers an opportunity to expand access, streamline workflows and address staffing challenges, provided they stay proactive about compliance, communication, and, above all, patient safety.

As the regulatory landscape continues to evolve, those who adapt early and thoughtfully will best position themselves to make the most of this new flexibility. If you have any questions regarding the implementation of AB 460, please contact Jonathan Dolgin.