Since 1902 the continuing negligent treatment rule has been applied to medical malpractice claims to establish when the statute of limitations begins to run on a particular cause of action. The rule is typically used in cases where the parties have engaged in a course of dealing over a period of time and the wrong complained of has stretched over all or part of this period.
J. R. Zepkin,
Virginia's Continuing Negligent Treatment Rule: Farely v. Goode and Fenton v. Danaceau,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol15/iss2/2