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U.S. Department of Health and Human Services

Radiation-Emitting Products

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Radiologic Technologist Continuing Education

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Citation:

900.12(a)(2)(iii)(A) and (C): Continuing Education Requirements:

(A) Following the third anniversary date of the end of the calendar quarter in which the requirements of paragraphs (a)(2)(i) and (a)(2)(ii) of this section were completed, the radiologic technologist 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 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.

(C) At least six of the continuing education units required in paragraph (a)(2)(iii)(A) of this section shall be related to each mammographic modality used by the technologist.

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 received after October 1, 1994 in certain cases.

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, 1997, the relevant continuing education credits for each person would be those earned from November 10, 1994, to November 10, 1997.

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, 1997, the relevant continuing education credits for each person would be those earned from October 1, 1994, through September 30, 1997.

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 radiologic technologists providing services to it. However, this is not required.

Questions:
  1. The American Society of Radiologic Technologists (ASRT) will provide to their members a computerized printout of the continuing education credits earned by ASRT-member technologists. Is this type of documentation acceptable for MQSA requirements?
  2. How is an individual’s starting date for beginning to meet the MQSA continuing requirements determined?
  3. 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?
  4. Are there specific areas that are acceptable for continuing medical education?
  5. If an individual publishes a paper in mammography, is it acceptable to use this paper for continuing medical education? How many units may that individual obtain?
  6. Under the final regulations, if less than 36 months have passed since a radiologic technologist’s starting date initially qualified to work independently, will he/she still be evaluated for continuing education during an inspection?
  7. For physicians, there is Category I and II continuing medical education (CME). For technologists, there are Category A and B continuing education units (CEU). Under the final regulations, physicians can only count Category I CME to meet their requirements. Will technologists be similarly restricted to counting only Category A CEU?
  8. If radiologic technologists 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?
  9. 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?
  10. How will the counting periods for continuing education relating to new mammographic modalities be synchronized with the general continuing education requirement?
  11. I'm a radiologic technologist and use only one mammographic modality (screen-film) at my facility. Will I have to document six CME/CEU credits in screen-film mammography as part of the 15 general mammography CME/CEU credits?
  12. Can time spent directly supervising other personnel, or being directly supervised, count toward the continuing education requirement?
  13. I qualified as an MQSA radiologic technologist in the past and have been performing mammography for several years. I recently passed the test for the ARRT(M) certificate. Can I claim 24 CEU credit hours for earning this certificate toward my continuing education requirement?