This exception prevents the statute of limitation's clock from ticking when the alleged harm is the result of a continuing tort. Continuous treatment for purposes of the exception must consist of treatment for the same or related illnesses or injuries. Even if Bendt had continued to medically treat Liffengren after her surgery, her cause of action would still turn on the nature of the condition for which she was being treated, not a general patient-physician relationship. Continuous treatment is not held to be synonymous with the continuing patient-physician relationship. While the termination of the treatment can be the time of accrual where there is no affirmative act of negligence and the injury results from the course of treatment, the general rule is that the statutory period is not postponed when there is a specific act of negligence even though the physician continues to treat the patient as long as the condition is not aggravated by it.
Continuous treatment involves more than a physician-patient relationship.
There must be ongoing treatment of a medical condition. Bendt performed the single procedure of the laparoscopy. When Liffengren began to feel pain and discomfort after the procedure, she went back to Bendt who immediately recognized the problem and consulted Yamada, a urologist. After Yamada placed the stent in Liffengren's ureter, her condition was corrected, and she was discharged from the hospital on October 10, 1994. She did not see Bendt again after her discharge, thus no doctor-patient relationship continued because she never returned to him for further treatment of this condition.