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?
No. As long as the facility is MQSA certified, there is nothing in the MQSA or FDA’s regulations that will interfere with training in mammography. Student technologists can receive classroom and practical training in a variety of ways. Student technologists who do not yet meet the requirements established under MQSA may perform actual examinations as part of the training so long as another technologist who does meet the MQSA requirements is present in the room to supervise (i.e. direct supervision) and, if necessary, corrects the student in the conduct of the examination. 21 C.F.R. 900.12(a)(2)(ii).