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U.S. Department of Health and Human Services

Radiation-Emitting Products

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Medical Physicist Continuing Education

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Citation:

900.12(a)(3)(iii)(A): Continuing education. Following the third anniversary date of the end of the calendar quarter in which the requirements of paragraph (a)(3)(i) or (a)(3)(ii) of this section were completed, the medical physicist shall have taught or completed at least 15 continuing education units in mammography during the 36 months immediately preceding the date of the facility’s annual inspection or the last day of the calendar quarter preceding the inspection or any date between the two. The facility shall choose one of these dates to determine the 36-month period. This continuing education shall include hours of training appropriate to each mammographic modality evaluated by the medical physicist during his or her surveys or oversight of quality assurance programs. Units earned through teaching a specific course can be counted only once towards the required 15 units in a 36-month period, even if the course is taught multiple times during the 36 months.

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.

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/CEU received after October 1, 1994, in certain cases. (see Attestation - Acceptable Uses for Personnel Requirements)

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:  Additionally, if the facility so chooses, 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 personnel providing services to it. However, this is not required.

Medical physicists may receive credit for presenting courses/lectures and/or reading/writing articles/papers for journals as long as the articles/papers and the courses/lectures pertain to the diagnosis or treatment of breast disease or other areas that will aid facility personnel in improving the quality of mammography. FDA has no way of determining the proper amount of credit to give for any individual article/paper or course/lecture. However, an organization authorized to award credit can assess and document the appropriate amount of CME/CEU awarded. The medical physicist must get a letter or other documentation from the authorized organization stating how many CME/CEU’s are awarded and the date the credit was given. FDA would then accept the amount awarded toward the continuing education requirement.

Questions
  1. How is an individual’s starting date for beginning to meet the MQSA continuing requirements determined?
  2. Does the starting date ever change due to personnel 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?
  3. Are there specific areas that are acceptable for continuing medical education?
  4. 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?
  5. Under the regulations, if less than 36 months have passed since a medical physicist’s starting date, will he/she still be evaluated for continuing education during an inspection?
  6. May medical physicists count general medical physics continuing education not related to mammography or general continuing education in mammography unrelated to medical physics?
  7. If medical physicists 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 those personnel who have left the facility but returned later, to provide mammography services?
  8. Under FDA's interim regulations, when personnel were found deficient for not having at least 15 continuing medical education (CME) credits or units in the previous 36 months, they were given up to 90 days to obtain this training while continuing to work at a mammography facility without direct supervision. Will this 90-day period be continued under FDA's final regulations?
  9. How will the counting periods for continuing education relating to new mammographic modalities be synchronized with the general continuing education requirement?
  10. I'm a medical physicist and evaluate only one mammographic modality (screen-film). Will I have to document CME/CEU credits in screen-film mammography as part of the 15 general mammography CME/CEU credits?
  11. Can time spent directly supervising other personnel, or being directly supervised, count toward the continuing education requirement?