Radiation-Emitting Products

Direct Supervision of RTs and MPs (Definition)

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Citation:

900.2(o)(2): Direct Supervision means that: During the performance of a mammography examination or survey of the facility’s equipment and quality assurance program, the supervisor is present to observe and correct, as needed, the performance of the individual being supervised who is performing the examination or conducting the survey.

Discussion:

The goal of direct supervision is to provide reasonable assurance that any mistakes made by the radiological technologist or physicist being supervised are corrected before patients are irradiated or harm is done to the patient.

Questions:

  1. Under what conditions may students or trainees work at facilities (performing mammographic examinations, or conducting medical physicist surveys) to obtain knowledge and experience prior to meeting the appropriate initial qualifications?
  2. What does it mean to be under the direct supervision of a qualified radiologic technologist?
  3. What does it mean to be under the direct supervision of a qualified medical physicist?
  4. During annual MQSA inspections, mammography personnel are sometimes found to not meet one or more of the personnel qualifications. May this individual (medical physicist, radiologic technologist) continue to lawfully provide mammography services to the facility?
  5. If personnel, such as radiologic technologists or medical physicists do not start working directly in mammography after meeting all their initial requirements, but decide to start working at a mammography facility later, what must they do to make sure they are in compliance with MQSA? What should facilities do before allowing new personnel, including locum tenens or those personnel who have left the facility but returned later, to provide mammography services?
  6. In a radiology training program with a mammography curriculum, would the facility be in non-compliance for letting student technologists show competency in performing mammography on live patients?
  7. Do general supervisors of radiologic technologists or medical physicists have to meet any requirements under MQSA?
  8. What are the required minimum qualifications for the supervisor of an individual who is performing surveys to meet the initial experience requirement or to requalify after failing to meet the continuing experience requirement?
  9. Technologist A is under the direct supervision of technologist B who works at another facility. Technologist B provides a letter documenting the number of examinations for which he/she provided direct supervision. Must technologist B also include documentation showing that he/she is a qualified radiologic technologist?
  10. Physicist A is under the direct supervision of physicist B who works at another facility. Physicist B provides a letter documenting the number of surveys for which he/she provided direct supervision. Must physicist B also include documentation showing that he/she is a qualified medical physicist?
  11. If the person providing direct supervision is found to be unqualified, how does that affect the status of the person being supervised?

Inspector Instructions:

Personnel who have met the initial requirements and are undergoing requalification after failing to meet the continuing requirements should not be considered trainees. Therefore, their names and associated information should be collected and recorded in the inspection record. The inspector should indicate the person’s requalifying status in the remarks section. When queried regarding requalifying personnel’s continuing requirements, the inspector should enter an "X."

Documentation: It will generally be sufficient if the technologist’s file contains a letter, table, or printout from each facility at which he or she performs mammography examinations, signed by a responsible facility official or the person performing the direct supervision. The document should state who provided the direct supervision and that the technologist performed a given number of examinations at that facility in a given time period. It is assumed that these numbers are based upon more extensive records, such as facility logs, that can be reviewed if there are any questions. The facility logs themselves can then be used as documentation. Provision of summary letters, tables, or printouts will speed up the inspection and rarely will the more detailed records be requested.

Documentation: It will generally be sufficient if the medical physicist’s file contains a letter, table, or printout from the surveying organization or each facility at which he or she performs mammography surveys, signed by a responsible organization or facility official or the person performing the direct supervision. The document should state who provided the direct supervision and that the medical physicist performed a given number of surveys of mammography facilities/units in a given time period. It is assumed that these numbers are based upon more extensive records, such as survey reports, that can be reviewed if there are any questions. The survey reports themselves can then be used as documentation. Provision of summary letters, tables, or printouts will speed up the inspection and rarely will the more detailed records be requested.

 

Page Last Updated: 07/09/2014
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