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U.S. Department of Health and Human Services

Radiation-Emitting Products

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Reestablishing the Medical Physicist Continuing Education Requirement

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Citation:

900.12(a)(3)(iv)(A): Medical physicists who fail to maintain the required continuing qualifications of paragraph (a)(3)(iii) of this section may not perform the MQSA surveys without the supervision of a qualified medical physicist. Before independently surveying another facility, medical physicists must reestablish their qualifications as follows: (A) Medical physicists who fail to meet the continuing educational requirements of paragraph (a)(3)(iii)(A) of this section shall obtain a sufficient number of continuing education units to bring their total units up to the required 15 in the previous 3 years.

Discussion:

Requalification does not affect or change the date on which such individuals met their initial qualification requirements, therefore, the starting dates on which such individuals must meet their continuing requirements remains the same.

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

Questions:
  1. 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?