Radiation-Emitting Products

Interpreting Physician Continuing Education

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Citation:

900.12(a)(1)(ii)(B): All interpreting physicians shall maintain their qualifications by meeting the following requirement: Following the third anniversary date of the end of the calendar quarter in which the requirements of paragraph (a)(1)(i) of this section were completed, the interpreting physician shall have taught or completed at least 15 category I continuing medical education units in mammography during the 36 months immediately preceding the date of the facility’s annual MQSA inspection or the last day of the calendar quarter preceding the inspection or any date in between the two. The facility will choose one of these dates to determine the 36-month period. This training shall include at least six category I continuing medical education credits in each mammographic modality used by the interpreting physician in his or her practice.

Discussion:

The term “starting date” is used to describe the date on which an interpreting physician, radiographic technologist, or medical physicist has met all initial MQSA requirements and must begin to meet the continuing requirements for his or her specialty.

Any of the following options may be used to determine if the continuing education requirement has been met:

Option 1:  The inspector counts back 36 months from the date of the inspection and includes all applicable continuing education credits received by each individual during that 36-month period. For example, if the inspection is conducted on November 10, 1999, the relevant continuing education credits for each person would be those earned from November 10, 1996, to November 10, 1999.

Option 2:  The inspector counts back 36 months from the end of the full calendar quarter immediately preceding the inspection date and includes all applicable continuing education credits received by each individual during that 36-month period. For the inspection date of November 10, 1999, the relevant continuing education credits for each person would be those earned from October 1, 1996, through September 30, 1999.

Option 3:  Inspectors may also count back 36 months from any date between the inspection date and the end of the previous full calendar quarter, and count the applicable continuing education received by each individual during that period towards meeting the continuing education requirement.

FDA recommends that the facility try to consistently use the same option for all interpreting physicians providing services to it. However, this is not required.

Copies of certificates earned or other documentation from the training provider will suffice for the continuing education qualification. FDA will continue to accept a limited form of attestation for CME received after October 1, 1994 in certain cases.

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Questions:
  1. Tumor boards are meetings in which cases of cancer or possible cancer are discussed by groups of physicians who may represent several specialties. In the case of possible breast cancer, mammograms may be reviewed during the discussion but the bulk of the time may be spent in discussing other issues such as follow-up actions. May interpreting physicians count their tumor board attendance time towards meeting the MQSA continuing medical education requirements? If so, how much credit should be given?
  2. How do I convert semester hours to hours of CME?
  3. Can I receive credit for presenting courses/lectures and/or reading/writing articles/papers?
  4. How is an individual’s starting date for beginning to meet the MQSA continuing requirements determined?
  5. A physician had over three months of training in mammography during residency, and has been reading and interpreting mammograms at a facility for several years. He or she has now passed the ABR certification exam. Will this change the starting date for the physician's continuing experience and continuing medical education?
  6. Does the starting date ever change, due to physicians taking time off after they qualify or if they re-qualify when they are found to be deficient for either continuing experience or continuing education?
  7. Under the regulations, if less than 36 months have passed since an interpreting physician’s starting date, will they still be evaluated for continuing education during an inspection?
  8. If a facility uses locum tenens interpreting physicians and the locum tenens is not working at the facility when it is inspected, must the facility have their continuing experience and continuing medical education updated quarterly or continuously, like the other (regular) interpreting physicians?
  9. Are there specific areas that are acceptable for continuing medical education?
  10. If an individual publishes a paper in mammography, is it acceptable to use that paper for continuing medical education? How many units may that individual obtain?
  11. If interpreting physicians do not start working directly in mammography after meeting the 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?
  12. Under FDA's interim regulations, when physicians were found deficient for not having at least 15 mammography CME in the previous 36 months, they were given up to 90 days to obtain this education while continuing to work at a mammography facility without direct supervision. Will this 90-day period be continued after FDA's final regulations take effect on April 28, 1999?
  13. How will the counting periods for continuing education relating to new mammographic modalities be synchronized with the general continuing education requirement?
  14. I'm an interpreting physician and use only one mammographic modality (screen-film) at my facility. Will I have to document six category I CME credits in screen-film mammography as part of the 15 general mammography CME credits?
  15. Can time spent directly supervising other personnel, or being directly supervised, count toward the continuing education requirement?

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Page Last Updated: 07/25/2014
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